The OECD BEPS Action Plan - Implications for the Tax Viability of Centre-Led Transfer Pricing Structures
Article from: OGEL 4 (2015), in Taxation
Abstract
The current debate on Base Erosion and Profit Shifting (BEPS) will have a significant impact on international taxation. One of the main targets of the OECD reform agenda is to address the challenge of valuating intangibles in the context of transfer pricing in order to ensure that transfer pricing outcomes are in line with value creation. This paper illustrates the fundamental impact of reform agenda on the viability of established transfer pricing structures. The OECD's proposal to extend the scope for applying the profit split method is particularly likely to impair the ...