MDW summarizes the key changes proposed by the UK in its transfer pricing law and administrative guidance.
Policy Update
MDW summarizes the key changes proposed by Canada in its transfer pricing law and administrative guidance.
OECD – Digital Taxes
MDW’s bulletin summarizes the OECD’s Blueprint on digital taxes for 2021 or 2022 once a consensus is reached among participating nations.
OECD – Financial Transactions
The OECD issued a new chapter for pricing financial transactions – e.g., loans, cash pooling, hedging, guarantees, captive insurance, and rates of return.
OECD – Cost Plus Models
MDW bulletin explains the new concerns and additional steps needed for multinational companies that use cost plus models in their corporate tax structure.
OECD – Financial Transactions
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
OECD – Profit Splits
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.
OECD – Intangibles
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.