OECD

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 OECD regarding Digitalization of the Economy Consultation

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.

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.

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