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PwC response to OECD on attribution of PEs

PwC's submitted response to the OECD for PricewaterhouseCoopers International Limited on behalf of its network of member firms welcoming the opportunity to comment on the OECD’s second Public Discussion Draft on Additional Guidance on the Attribution of Profits to Permanent Establishments and requesting a chance to speak at the subsequent public consultation.

PwC response to OECD on profit splits

PwC submitted the response attached to the OECD for PricewaterhouseCoopers International Limited on behalf of its network of member firms welcoming the opportunity to comment on the OECD’s Public Discussion Draft on the Revised Guidance on Profit Splits and requesting a chance to speak at the subsequent public consultation.

Transfer Pricing - Treasury function considerations in the post BEPS environment

Changes to the global transfer pricing environment post-BEPS have required taxpayers and practitioners alike to reconsider transfer pricing policies for intra-group operational transitions. The impact of these changes on intra-group treasury transactions is no different. However, the challenges for the latter are amplified due to a combination of the ultra-low interest rate environment and a wide dispersion in cash management policies that tax authorities observe upon audit review. As a result, traditional treasury pricing mechanisms now need to be reviewed to assess the impact of the evolving regulatory and controversy developments.