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BEPS: Is the OECD Now at the Gates of Global Formulary Apportionment?

See our most recent article published in Intertax available here (reproduced with permission). To see more of our work, visit DRTP publications page here. Robert Robillard, Ph.D., CPA, CGA, MBA, M.Sc. Econ. Senior Partner, DRTP Consulting Inc. 514-742-8086; robertrobillard...
Posted by DRTP On 15 June 2015

Canada Signs Multilateral Competent Authority Agreement

From the Canadian government website: "The Honourable Kerry-Lynne D. Findlay, P.C., Q.C., M.P, Minister of National Revenue, today signed the international Multilateral Competent Authority Agreement (MCAA), an important step towards implementing the Common Reporting Standard...
Posted by DRTP On 8 June 2015

“Hard-to-Value Intangibles”: New OECD Discussion Draft Released

From the OECD website: "04/06/2015 - Public comments are invited on a discussion draft which deals with work in relation to Action 8 of the Action Plan on Base Erosion and Profit Shifting(BEPS). Action 8...
Posted by DRTP On 5 June 2015

BEPS Action 3 Missing in Action: CFC Rules or Global Formulary Apportionment?

See our latest article published in the Bloomberg BNA Tax Management Transfer Pricing Report here (reproduced with permission). To see more of our work, visit DRTP publications page here. Robert Robillard, Ph.D., CPA, CGA, MBA, M.Sc....
Posted by DRTP On 4 June 2015

OECD BEPS Action 8 (ref: Cost contribution arrangements): Public Comments Received

From the OECD website: "01/06/2015 - On 29 April 2015, the OECD invited comments from interested parties on a discussion draft on revisions to Chapter VIII of the Transfer Pricing Guidelines on Cost Contribution Arrangements.  This work...
Posted by DRTP On 1 June 2015