MDW bulletin explains the new concerns and additional steps needed for multinational companies that use cost plus models in their corporate tax structure.
The OECD released a discussion draft on financial transactions – e.g., loans, cash pooling, hedging, guarantees, captive insurance. Public comments are due by 7 Sept 2018
The OECD released new guidance on profit split methods including 16 examples to show how the guidance can be followed for using a method that historically was not used very often.
The OECD released new guidance on hard-to-value intangibles governing when – years later – tax authorities can use actual results to test the assumptions used by taxpayers in the valuation of intangibles.
Matthew Wall of MDW submitted comments to the OECD’s latest revision of 2017 Discussion Draft for the guidance on profit splits.
Matthew Wall of MDW submitted comments to the OECD on the Discussion Draft for BEPS Action 8 implementation guidance on Hard-to-Value Intangibles.
Matthew Wall of MDW submitted comments to the OECD’s latest revision of 2016 Discussion Draft for the guidance on profit splits.
MDW explained the final revisions to the OECD Guidelines for Chapter VI on Intangibles states the legal owner of intangibles does not have the right to all of the intangible profits.
MDW explained taxpayers with a “cash box” in a low or no-tax jurisdiction must review the 2015 OECD Guidelines and might need to revise their corporate structure, transactions between related parties, or both, to mitigate the risk of a dispute.
Matthew Wall of MDW submitted detailed comments to the OECD on the BEPS Action 8, 9 and 10: Discussion Draft for Chapter I on transfer pricing for risk, recharacterisation and special measures.