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.
On November 7, TEI submitted comments to the Platform for Collaboration on Tax – a joint initiative of the World Bank, OECD, International Monetary Fund, and United Nations – regarding its draft transfer pricing documentation toolkit for developing countries.
On March 4th, TEI submitted comments to the OECD regarding its public consultation document entitled Addressing the Tax Challenges of the Digitalisation of the Economy. TEI will also participate in in the upcoming public consultation on March 13-14 in Paris.
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.
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.
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.
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.