2020-10-14

New transfer pricing principles (Actions 8-10) Overview of the final report BEPS Action 8, 9 and 10 Assure that transfer pricing outcomes are in line with value creation Action 8: Intangibles Wider and clearer definition of “intangibles” Introduction of a six step framework to analyse transfer pricing aspects of intangibles

Watch later. Beps Actions 8 – 10, Financial transactions Additional guidance is still to be provided to fully clarify transfer pricing issues related to financial transactions 3 supervision of the central treasury function at company C, also part of the MNE group. BEPS Action 5. Counter harmful tax practices more effectively, taking into account transparency and substance. The Federal Act on Tax Reform and AHV Financing (TRAF), which entered into force on 1 January 2020, abolished tax regimes that were no longer internationally recognised and introduced new, internationally accepted rules.; The spontaneous exchange of information on advance tax rulings Actions 8-10. Assure that transfer pricing outcomes are in line with value creation. Action 11.

Beps 8-10 summary

Actions 8-10 – Aligning transfer pricing outcomes with value creation. Action 11 – Measuring and monitoring BEPS. Action 12 — Mandatory disclosure rules. Action 13 – Guidance on transfer pricing documentation and country-by-country reporting.

It is recommended, 12 ‘The initial CFC legislation in 2001 referred to “controlled foreign entities” (CFEs) as opposed to CFCs, since it included foreign trusts as entities, whose income required attribution.

2 ExECutivE SuMMaRy ExECutivE SuMMaRy 3 ExEcUTIvE SUmmaRy inCREaSED COStS anD unCERtainty The BEPS Project will have direct and significant consequences for all internationally operating companies. it will increase compliance costs and global effective tax rates and is creating considerable strategic uncertainty.

Assure that transfer pricing outcomes are in line with value creation. Action 11. Establish methodologies to collect and analyse data on BEPS and the actions to address it.

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BEPS ACTIONS 8 - 10 Under the mandate of the Report on Actions 810 of the BEPS Action Plan - summary limited to two pages. should be addressed to the Tax Final report on BEPS Actions 8-10: Guidance for applying the arm’s length principle (including risk and recharacterization) October 15, 2015 On October 5, 2015, ahead of the G20 Finance Ministers’ meeting in Lima on October 8, the Organisation for Economic Co-operation and Development (OECD) On 23 May 2016, the OECD’s governing body, the OECD Council, approved the amendments to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (“OECD Guidelines”), as set out in the 2015 BEPS reports on Actions 8-10 and Action 13. A discussion draft on the changes to the OECD Guidelines was released on Action Items 8-10 of the BEPS Project specifically addresses the alignment of transfer pricing outcomes with value creation. Action Items 8- 10 were released in a single report that addresses transactions involving intangibles, risk, and capital transfers between group entities, and other high-risk transactions. Osler Submission to OECD in response to Public Discussion Draft on BEPS Actions 8-10 Financial Transactions 2018 Actions 8-10: Guidance for Tax Administrations on the Application of the Approach to Hard-to-Value Intangibles [A8] and Revised Guidance on the Application of the Transactional Profit Split Method [10] Actions 8-10: Transfer Pricing. Moves to align transfer pricing outcomes with value creation. Creates stronger guidelines to transactions involving the transfer pricing of intangibles and contractual arrangements.

16 Rapporteringen till OECD-DAC (1,4 procent av BNI) inkluderar även alla Biodiversity and Human Health, Summary of the State of Knowledge alla mål av Agenda 2030, särskilt följande mål: 1,3, 4, 5, 8, 10, 11, 16, 17.
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Action 11.

• risk and capital. • six step framework. intangibles as expressed by the OECD itself in the Summary of the Intangibles Actions 8-10 – 2015 Final Reports, Intangibles, Revisions to Chapter VI, p.
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BEPS Action 5. Counter harmful tax practices more effectively, taking into account transparency and substance. The Federal Act on Tax Reform and AHV Financing (TRAF), which entered into force on 1 January 2020, abolished tax regimes that were no longer internationally recognised and introduced new, internationally accepted rules.; The spontaneous exchange of information on advance tax rulings

Action 11. Establish methodologies to collect and analyse data on BEPS and the actions to address it. Action 12. Require taxpayers to disclose their aggressive tax planning arrangements. Action 13. Re-examine transfer pricing documentation. Action 14 BEPS TP & CbC reporting: EY Survey.

BEPS Action 13: Country implementation summary Last updated: February 11, 2019. 1 Master File / Local File: Country implementation summary Argentina (MF only) Australia Austria Belgium Bosnia and Herzegovina (Federation of Bosnia and Herzegovina) China Colombia

On 12 October 2020, the Organisation for Economic Co-operation and Development (OECD) released a series of major documents in connection with the ongoing G20/OECD project titled “Addressing the Tax Challenges of the Digitalisation of the Economy” (the BEPS 2.0 project).

all lines in document: Great Dividing BEPS – ett arbete inom OECD.