TEI Files Comments on OECD Pillar One and Pillar Two Blueprints
On December 13, TEI submitted comments to the OECD regarding its BEPS Project Pillar One and Pillar Two Blueprints. TEI’s comments focused on the specific questions posed by the OECD in its consultation document, including issues related to Amounts A and B under Pillar One, as well as the GloBE under Pillar Two.
TEI Comments on the OECD’s “GloBE” Proposal
On December 2, TEI filed comments responding to the OECD’s public consultation document entitled Global Anti-Base Erosion Proposal (“GloBE”) – Pillar Two, focusing on the need for states to withdraw unilateral measures, a strong binding dispute resolution mechanism, and clear ordering rules, among other things.
TEI Files Comments regarding the OECD Secretariat’s “Unified Approach” to Pillar One
On November 11, TEI submitted comments to the OECD Secretariat regarding its proposed “unified approach” to “Pillar One” of the tax challenges of the digitalization of the economy. TEI’s comments focused on the need for (i) the withdrawal of unilateral measures after a multilateral agreement, (ii) a multilateral dispute resolution mechanism; and (iii) reliance on taxpayer consolidated financial statements for purposes of the approach, among other subjects.
TEI Submits Comments to the Australian Treasury regarding Digital Economy Discussion Paper
On November 29th, TEI submitted comments to the Australian Treasury regarding its Discussion Paper on the digital economy and Australia’s corporate tax system.
TEI Submits Comments to the Treasury and IRS regarding Proposed Regulations under Section 965
On October 9th, TEI submitted comments to the Treasury and IRS regarding proposed regulations promulgated under the transition tax imposed by section 965, as amended by the Tax Cuts & Jobs Act enacted in 2017.
TEI Submits Comments to the OECD regarding the Transfer Pricing aspects of Financial Transactions
On September 6th, TEI submitted comments to the OECD regarding its public discussion draft under BEPS Actions 8-10 on the transfer pricing aspects of financial transactions.
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 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 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.