|Welcome to the September/October edition of the ONESOURCE Transfer Pricing newsletter, your monthly source for the latest transfer pricing news. Each edition will feature articles and insight to keep you apprised on current events in the transfer pricing industry, as well as exciting things we are working on at Thomson Reuters ONESOURCE.
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The OECD has released new guidance on transfer pricing documentation in response to Base Erosion and Profit Shifting (BEPS). This guidance will result in a significant shift of the overall dynamics of transfer pricing documentation. Read our latest report to learn more about these changes and how your organization can leverage intelligent technology to navigate the transfer pricing environment.
The OECD has released its chapters on seven of the proposed Base Erosion and Profit Shifting action plans including the chapter on intangibles and the chapter on documentation including country by country reporting.
The Russian affiliate of British American Tobacco had earlier been challenged on its transfer pricing by its minority shareholders. The Russian tax authorities have recently challenged its intercompany interest deductions. The various challenges to the transfer pricing show that multinationals need to be able to defend not only their intercompany pricing for goods but also other intercompany pricing issues both before the national tax authorities but also to any minority shareholders of their affiliates.
Question: Action 8 under the OECD Base Erosion and Profit Shifting plan is entitled, “Guidance on Transfer Pricing Aspects of Intangibles.” What are the key takeaways from this guidance?