OECD: Discussion Drafts on Attribution of Profits to PE and Revised Guidance on PSM
Two discussion drafts were released on July 4, 2016 by the OECD:
- Attribution of Profits to Permanent Establishments, “which deals with work in relation to Action 7 (“Preventing the Artificial Avoidance of Permanent Establishment Status”) of the BEPS Action Plan.”
- Revised Guidance on Profit Splits, “which deals with work in relation to Actions 8-10 (“Assure that transfer pricing outcomes are in line with value creation”) of the BEPS Action Plan.”
Comments may be submitted to the OECD by 5 September, 2016 to TransferPricing@oecd.org in Word format.
The OECD also indicates:
“Comments in excess of ten pages should attach an executive summary limited to two pages.”
Duly noted… 🙂
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