OECD

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 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 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 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.

TEI Comments on BEPS Multilateral Instrument

On June 29, 2016, TEI filed a comment letter with the OECD regarding its request for input on Development of a Multilateral Instrument to Implement the Tax Treaty related BEPS Measures under Action 15 of the OECD’s base erosion and profit shifting (BEPS) project.

TEI Comments on Revised OECD Treaty Abuse Discussion Draft

On June 16, 2015, TEI submitted comments on the OECD revised discussion draft on BEPS Action 6: Prevent Treaty Abuse. The Institute's comments focused on the need for certainty in the determination of when taxpayers will qualify for treaty benefits so businesses can plan their cross-border operations. TEI also noted, among other things, that the proposed changes to the OECD model tax convention will create taxation where none has previously existed, in contravention of the traditional purpose of tax treaties to eliminate double taxation and prevent tax evasion.

Close