Considerable media attention has been given to whether international tax rules can keep pace with modern business practices, the globalisation of corporations and the digital economy. This comes from a concern that profits are not being taxed in the jurisdictions in which they are commercially made. Transfer pricing policy has therefore taken on added significance.
In 2013 the G20 and the Organisation for Economic Co-operation and Development (“OECD”) began the Base Erosion and Profit Shifting (“BEPS”) project with a view to putting a stop to profit shifting. Subsequently, a wealth of information has been published following the October 2015 final reports on the 15 BEPS actions. This covers areas for suggested change in international tax rules and tax treaties which will have significant implications for Multinational Enterprises (“MNEs”). The proposed way forward is improved transparency in relation to the global activities.
For more information please click on the following link to view our Corporate Member, Blick Rothenberg's summary of the latest developments in relation to transfer pricing regulations and documentation: