The Future of the Profit Split Method PDF Download
Are you looking for read ebook online? Search for your book and save it on your Kindle device, PC, phones or tablets. Download The Future of the Profit Split Method PDF full book. Access full book title The Future of the Profit Split Method by Gabriella Cappelleri. Download full books in PDF and EPUB format.
Author: Gabriella Cappelleri
Publisher: Kluwer Law International B.V.
ISBN: 9403524316
Category : Law
Languages : en
Pages : 341
Get Book Here
Book Description
The Future of the Profit Split Method Edited by Robert Danon, Guglielmo Maisto, Vikram Chand & Gabriella Cappelleri Among the various transfer pricing methods, the profit split method (PSM) is under the spotlight after the OECD’s Base Erosion and Profit Shifting (BEPS) project. However, both expert analysis and experience indicate that this method is not straightforward either for taxpayers to apply or for tax administrations to evaluate. In this thorough and detailed commentary – the first book to analyse this increasingly adopted transfer pricing method – notable scholars and practitioners working in the international tax community express their views on the method, answering some unresolved questions and highlighting issues that are still open and pending, especially in light of the digitalization of the economy. Crucial issues covered by the contributors include the following: choice of the appropriate splitting factors, their relative weights, and valuation of the contributions; uncertainties and outcomes potentially not aligned with the arm’s-length standard; possible role of assessments made by the European Commission on State aid; nexus with the work done by the EU Joint Transfer Pricing Forum; impact of profit split on indirect taxes (VAT/customs tax/excise tax); and application to digital business models and, in general, to the digitalized economy. Moreover, relevant experience of applying this method in France, Germany, Italy, Spain, Switzerland, the United Kingdom, and the United States is provided. A concluding chapter also deals with selected industry experiences. Due to a high level of uncertainty in alignment with international guidance in the application of the PSM – and to the underdeveloped nature of current literature on the subject – there is a need for this book because both tax administrations and taxpayers, going forward, will apply the PSM extensively. The book is highly relevant for policymakers, tax administrations, practitioners and academics engaged in the areas of international taxation, transfer pricing and tax policy.
Author: Gabriella Cappelleri
Publisher: Kluwer Law International B.V.
ISBN: 9403524316
Category : Law
Languages : en
Pages : 341
Get Book Here
Book Description
The Future of the Profit Split Method Edited by Robert Danon, Guglielmo Maisto, Vikram Chand & Gabriella Cappelleri Among the various transfer pricing methods, the profit split method (PSM) is under the spotlight after the OECD’s Base Erosion and Profit Shifting (BEPS) project. However, both expert analysis and experience indicate that this method is not straightforward either for taxpayers to apply or for tax administrations to evaluate. In this thorough and detailed commentary – the first book to analyse this increasingly adopted transfer pricing method – notable scholars and practitioners working in the international tax community express their views on the method, answering some unresolved questions and highlighting issues that are still open and pending, especially in light of the digitalization of the economy. Crucial issues covered by the contributors include the following: choice of the appropriate splitting factors, their relative weights, and valuation of the contributions; uncertainties and outcomes potentially not aligned with the arm’s-length standard; possible role of assessments made by the European Commission on State aid; nexus with the work done by the EU Joint Transfer Pricing Forum; impact of profit split on indirect taxes (VAT/customs tax/excise tax); and application to digital business models and, in general, to the digitalized economy. Moreover, relevant experience of applying this method in France, Germany, Italy, Spain, Switzerland, the United Kingdom, and the United States is provided. A concluding chapter also deals with selected industry experiences. Due to a high level of uncertainty in alignment with international guidance in the application of the PSM – and to the underdeveloped nature of current literature on the subject – there is a need for this book because both tax administrations and taxpayers, going forward, will apply the PSM extensively. The book is highly relevant for policymakers, tax administrations, practitioners and academics engaged in the areas of international taxation, transfer pricing and tax policy.
Author: M. Kobetsky
Publisher:
ISBN:
Category :
Languages : en
Pages :
Get Book Here
Book Description
In 2018, the Organisation for Economic Co-operation and Development/Group of Twenty (OECD/G20) Inclusive Framework on base erosion and profit shifting (BEPS): action 10 issued revised guidance on the transactional profit-split method. Regrettably, the revised guidance failed to provide the opportunity for the profit-split method to be more often the most appropriate transfer-pricing method. The revised guidance expressly states that the lack of comparable uncontrolled transactions, by itself, is not a basis for the use of the profit-split method. Under the former guidance, the profit-split method was used infrequently. In the revised guidance, the threshold requirements for the use of the profit-split method are still restrictive. Consequently, it is likely that the profit-split method will rarely be the most appropriate transfer-pricing method. Nevertheless, the residual profit-split method is being considered for BEPS action 1, on the taxation of the digital economy. Two of the proposals under pillar 1 of the Inclusive Framework's 2019 short policy note involve the use of the residual profit-split method to allocate profits. These proposals involve new profit allocation rules that go beyond the arm's-length principle.
Author: Jeffery M. Kadet
Publisher:
ISBN:
Category :
Languages : en
Pages : 7
Get Book Here
Book Description
Recognizing the reality that multinational corporations are centrally managed and not groups of entities that operate independently of one another, the OECD base erosion and profit-shifting project is considering expanded use of the profit-split method. This article provides background on why expanded use of the profit-split method is sorely needed. In particular, resource-constrained tax authorities in many countries are unable to administer or intelligently analyze and contest transfer pricing results presented by multinational groups. Most importantly, this article suggests a simplified profit-split approach using set concrete and objective allocation keys for commonly used business models that should be welcomed by multinational groups and tax authorities alike.
Author: J.M. Kadet
Publisher:
ISBN:
Category :
Languages : en
Pages :
Get Book Here
Book Description
In this article, the authors discuss the future of the profit-split method.
![The Profit Split Method : Historical Evolution and BEPS Insights [part 1]. PDF](https://books.google.com/books/content/images/frontcover/sgGizgEACAAJ?fife=w80-h100)
Author: R. Petruzzi
Publisher:
ISBN:
Category :
Languages : en
Pages :
Get Book Here
Book Description
This article is the first of a three-part contribution that attempts to provide an outlook on the historical development, the status quo, and the future direction of the profit split method, especially by taking into account the outcome of the OECD/G20 base erosion and profit shifting (BEPS) project. This article particularly examines the latest OECD discussion draft, "Revised guidance on profit splits", and further discusses the direction that the discussion draft might lead to in the future, given the direct and immediate impacts the discussion draft might have on the future development of the profit split method.
![The Profit Split Method : Insights from BEPS Follow-ups [part 3]. PDF](https://books.google.com/books/content/images/frontcover/EeefzgEACAAJ?fife=w80-h100)
Author: R. Petruzzi
Publisher:
ISBN:
Category :
Languages : en
Pages :
Get Book Here
Book Description
This article is the third part of a three-part contribution that attempts to provide the historical development, status quo, and future direction of the profit split method, especially by taking into account the OECD/G20 base erosion and profit shifting (BEPS) project. This article ponders the role of the profit split method in the future BEPS work, namely the application within the 2008 OECD "Report on the attribution of profits to permanent establishments" and the possibility of it being a toolkit for developing countries.
![The Profit Split Method : a Holistic View of BEPS in Transfer Pricing [part 2]. PDF](https://books.google.com/books/content/images/frontcover/aKKfzgEACAAJ?fife=w80-h100)
Author: R. Petruzzi
Publisher:
ISBN:
Category :
Languages : en
Pages :
Get Book Here
Book Description
This article is the second part of a three-part contribution that attempts to provide the historical development, status quo, and future direction of the profit split method, especially by taking into account the OECD/G20 base erosion and profit shifting (BEPS) project. This article walks through the relevant BEPS developments on transfer pricing and presents the interplay between the profit split method and other transfer pricing aspects under the current BEPS system.
Author: Vikram Chand
Publisher:
ISBN:
Category :
Languages : en
Pages : 7
Get Book Here
Book Description
In this coauthored publication, the authors analyse whether the OECD's base erosion and profit shifting (BEPS) project would increase the use of the profit split method. After reviewing the current landscape in this context, the authors focus on situations in which the profit split method applies, the various approaches that can be used to split the profit among associated enterprises and reasons why the profit split method has been infrequently applied. Finally, the authors present their views on the application of the profit split method in light of the BEPS Action Plan.
Author: R. Robillard
Publisher:
ISBN:
Category :
Languages : en
Pages :
Get Book Here
Book Description
The author examines the OECD's guidance on the profit-split method from the introduction of the Transfer Pricing Guidelines in 1979 to today, emphasizing the consistency of the guidance on the determination of profits to split and pointing to a shift, one he sees as hazardous, in the guidance on the split of the profits.
Author: Wolfgang Schön
Publisher: Springer Science & Business Media
ISBN: 3642259804
Category : Law
Languages : en
Pages : 308
Get Book Here
Book Description
The taxation of multinational corporate groups has become a major concern in the academic and political debate on the future of international taxation. In particular the arm’s length standard for the determination of transfer prices is under increasing pressure. Many countries and international bodies are now taking a closer look at the use of transfer prices for profit shifting and are exploring alternative mechanisms such as formulary apportionment for the allocation of taxing rights. With regard to this topic, this volume is the first to offer a concise analysis of transfer pricing in the international tax arena from an interdisciplinary legal and economic point of view. Fundamentals such as the efficient allocation of resources within multi-unit firms and distortions between different goals of transfer pricing as well as different aspects of it in tax and corporate law, the traditional OECD approach and practical aspects concerning intangibles, capital and risk allocation are covered by outstanding authors.
