OECD publish BEPS discussion drafts on attribution of profits to PEs and revised guidance on profit splits
The OECD recently released discussion drafts on attribution of profits to permanent establishments and revised guidance on profit splits under the BEPS initiative.
Public comments are invited on the following discussion drafts:
- Attribution of Profits to Permanent Establishments, which deals with work in relation to Action 7 (“Preventing the Artificial Avoidance of Permanent Establishment Status”) of the BEPS Action Plan;
- Revised Guidance on Profit Splits, which deals with work in relation to Actions 8–10 (“Assure that transfer pricing outcomes are in line with value creation”) of the BEPS Action Plan.
Interested parties are invited to send comments on these discussion drafts by 5 September 2016 by e-mail to TransferPricing@oecd.org.