EMEA Direct Tax Committee

The European Direct Tax Committee covers income-based tax aspects of European operations, including tax treaty matters, and develops the Institute’s positions and submissions to taxing authorities in European countries, as well as the European Union and OECD.

TEI Comments on Scope of Revisions to OECD Transfer Pricing Guidelines

On June 19, TEI submitted comments to the OECD regarding the scope of future revisions to Chapters IV and VII of the OECD’s transfer pricing guidelines. TEI’s comments focused on the practical aspects of any future guidance.

TEI Comments on the European Commission’s Digital Economy Tax Proposals

On May 15, TEI submitted comments regarding the European Commission’s proposals to define the concept of a “significant digital presence” for corporate income tax purposes and impose an interim digital services tax.

TEI Comments on European Commission Digital Economy Survey

On January 2, TEI submitted responses to the European Commission’s survey regarding “fair taxation of the digital economy,” disagreeing with the Commission’s proposed alternatives to taxing digital commerce.

TEI Comments on Taxation of Offshore Indirect Transfer

On October 19, TEI submitted comments to the Platform for Collaboration on Tax regarding the Platform’s draft toolkit on the taxation of offshore indirect transfers.

TEI Comments on OECD Request Regarding the Digitalization of the Economy

On October 12, TEI submitted comments to the OECD regarding their request for input on the tax challenges of the digitalization of the economy, including an interim report to be submitted to the G20 finance ministers.

TEI Comments on OECD Discussion Draft Regarding Revised Profit Split Guidance

On September 8, TEI filed comments with the OECD regarding its public discussion draft on revised guidance on the use of profit splits.

TEI Comments on OECD Hard-to-Value-Intangibles Draft

On June 29, TEI submitted comments to the OECD on its public discussion draft regarding Implementation Guidance on Hard-to-Value Intangibles.

TEI Participates in IRS Country-by-Country Association Roundtable

On January 12, 2017, TEI Executive Director Eli Dicker and Tax Counsel Benjamin Shreck participated in a roundtable discussion of the IRS’s administration of country-by-country (CbC) reporting. The discussion focused on the CbC forms, instructions and guidance, external communication and outreach, compliance and enforcement issues, as well as international exchange and use of CbC information.

TEI Participates in OECD BEPS Public Consultations

On October 11-12, 2016, TEI Tax Counsel Ben Shreck participated in the OECD’s Public Consultations regarding revised OECD guidance on the use of the profit split method for transfer pricing purposes and the attribution of profits to permanent establishments under the OECD’s BEPS Project. TEI’s planned intervention at the Consultation addressed profit split factors. It is expected that the OECD will issue final guidance on these two topics by the end of 2016.

TEI Comments on OECD Profit Split Guidance

On September 4, 2016, Tax Executives Institute, Inc., filed a letter with the OECD commenting on its public discussion draft regarding Revised Guidance on Profit Splits. The Institute's comments focused on the need for clear guidance regarding how the transaction profit split method of setting transfer prices should be applied in practice and the limited settings in which the method is appropriate.