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DRTP Comments on Chapter I of the Transfer Pricing Guidelines (BEPS risk, recharacterisation and special measures)

The OECD recently released the Public comments received on discussion draft on Actions 8, 9 and 10 : revisions to Chapter I of the Transfer Pricing Guidelines (Including risk, recharacterisation and special measures) of the...
Posted by DRTP On 19 February 2015

Thinking About Change: A New Fixed Point

Whoever wants to observe change needs a fixed point. Fixed points are everywhere and indeed, they are essential when one thinks about it, whether it is a date in time like one’s birth date, or...
Posted by Stéphane Dupuis On 18 February 2015

DRTP Comments on the Transfer Pricing Aspects of Cross-Border Commodity Transactions (BEPS Action 10)

The OECD recently released the Public comments received on discussion draft on the transfer pricing aspects of cross-border commodity transactions (BEPS Action 10). The opinions expressed in the document below are those of the author....
Posted by DRTP On 18 February 2015

OECD BEPS Public Consultation on Transfer Pricing Matters

From the OECD website: "The OECD will hold a public consultation event on transfer pricing matters on 19-20 March 2015 at the OECD Conference Centre in Paris, France. The event will concentrate on matters covered...
Posted by DRTP On 17 February 2015

DRTP Comments on the PSM Use in the Context of Global Value Chains (BEPS Action 10)

The OECD recently released the Public comments received on the discussion draft on the use of profit splits in the context of global value chains (BEPS Action 10). Here are DRTP Consulting comments. The opinions...
Posted by DRTP On 16 February 2015