Transfer Pricing Links 11/04/2014

OECD : Public comments received on discussion draft on Action 6 (Prevent Treaty Abuse) of the BEPS Action Plan

“11/04/2014 – On 14 March 2014, the OECD invited comments from interested parties on the discussion draft on Action 6 (Prevent Treaty Abuse) of the BEPS Action Plan. The OECD now publishes the comments received.”


Country-by-Country Template Won’t Require Entity-by-Entity Financial Details, Andrus Says Transfer Pricing Report (K A Bell, BNA Bloomberg)

“March 31 –A proposed country-by-country reporting template will not require multinational companies to break down financial details by legal entity, an official with the Organization for Economic Cooperation and Development announced March 31.

Joseph Andrus, head of the OECD’s transfer pricing unit, said that Working Party No. 6 has tentatively “concluded that the CbC template will only require aggregate countrywide reporting of financial information as opposed to legal-entity-by-legal-entity reporting.””


Multinationals brace for tax overhaul The Globe & Mail (B McKenna)

“Multinationals are bracing for sweeping changes to the way countries tax them and gather data as Canada and other developed countries join in a global corporate tax crackdown.

The Organization for Economic Co-operation and Development is busily drafting a set of common global standards for taxing multinationals, slated to be rolled out starting in September.”


The Apple and the Caterpillar Transfer Pricing Report (A Parker, BNA Bloomberg)

“On April 1, Sen. Carl Levin held the latest in a series of hearings examining what he claims are blatant loopholes in the international tax system.

Previous hearings had called executives from Microsoft and Apple to the carpet, forcing them to defend their tax planning strategies which result in billions of dollars being earned in off-shore subsidiaries. But this time, Levin’s target was Caterpillar Inc.–not a glitzy Internet or computer company, but a Midwestern manufacturer which has been making construction equipment for nearly a century.”


Robert Robillard, CPA, CGA, MBA, M.Sc. Econ.
Senior Partner, DRTP Consulting Inc.
514-742-8086; robertrobillard “at”

DRTP Consulting Inc. solutions go beyond transfer pricing and international tax solutions. This blog post originally appeared at The information in this blog post is general information only. Data and information come from sources believed to be reliable but complete accuracy cannot be guaranteed. DRTP Consulting Inc. or the author are not responsible or liable for any error, omission or inaccuracy in such information. Readers should seek advice and counsel from DRTP Consulting Inc. as required.

Posted by drtp On 28 May 2014