BEPS HTVI Guidance.pdf

438994-BEPS-implementation-guidance-on-hard-to-value-intangibles-discussion-draft.pdf
Preview of BEPS HTVI Guidance
🔗 Source: web-archive.oecd.org
📊 Size: 114 KB
👤 Author: Aitor Navarro Ibarrola
⬇️ Downloads: 271

Summary

The OECD has released a public discussion draft on the implementation guidance for tax administrations on hard-to-value intangibles (HTVI) under BEPS Action 8. The guidance aims to prevent base erosion and profit shifting by ensuring tax administrations can determine if pricing arrangements are at arm's length. The approach allows tax administrations to consider ex post outcomes as presumptive evidence of the appropriateness of ex ante pricing arrangements, while giving taxpayers the opportunity to rebut this evidence. The guidance includes examples and explanations of the interaction with the mutual agreement procedure under applicable treaties. Comments are invited by June 30, 2017.

Description

The OECD has released a public discussion draft on the implementation guidance for tax administrations on hard-to-value intangibles (HTVI) under BEPS Action 8.

Technical Information

  • File Format: PDF
  • File Size: 114 KB
  • Pages: 8
  • Language: EN
  • Author: Aitor Navarro Ibarrola
  • Total Downloads: 271
  • Last Updated: 4 weeks ago

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