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Transfer Pricing Updated draft APA template released by IRS offers taxpayers more options

The IRS's Advance Pricing and Mutual Agreement Program (APMA) have released a new template that taxpayers must use when requesting an advance pricing agreement (APA) in the US. The new template updates a proposed draft template that the IRS made available for public discussion in September 2017. An announcement explaining the new template and the IRS response to public comments preceded its release.

New Dutch transfer pricing decree implements OECD guidelines

The Decree provides further guidance on application of the arm's length principle and aims to incorporate recent changes following the OECD BEPS project and related changes in the 2017 OECD Transfer Pricing Guidelines. The Decree emphasises the importance of conduct over contract and functions to control risks, as well as explicitly calling attention to penalties.

Updated draft APA template released by IRS offers taxpayers more options

On 14 May, the IRS's Advance Pricing and Mutual Agreement Program (APMA) released a new template that taxpayers must use when requesting an advance pricing agreement (APA) in the US. The new template updates a proposed draft template that the IRS made available for public discussion in September 2017. An announcement explaining the new template and the IRS response to public comments preceded its release.

OECD guidance on attribution of profits to PEs leaves unanswered questions

On 22 March, the OECD released a final report containing additional guidance on attribution of profits to permanent establishments (the Report). The Report sets forth high-level principles for attributing profits to permanent establishments (PEs), following the two discussion drafts published in July 2016 and June 2017 and public discussions held in November 2016 and November 2017. The Report provides further guidance on the Final Reports on Base Erosion and Profit Shifting (BEPS) published in October 2015.

OECD, BEPS and Permanent Establishments

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.

TP Documentation in the Middle East?

This Tax Insight, from Transfer Pricing, analyses some of the potential benefits for multinationals operating in the Middle East of preparing and maintaining a TP Masterfile and TP local files on a selective basis.