On September 8, 2017, TEI submitted comments to the OECD on its recent public discussion draft regarding revised guidance on the use of profits splits for transfer pricing purposes. TEI’s comments focused on the need for additional and more detailed examples in the final OECD guidance, as well as the need for greater recognition that losses among related parties in transfer pricing transactions also need to be split, among other things. The Institute’s comments were prepared under the aegis of TEI’s European Direct Tax Committee, whose Chair is Giles Parsons. Ben Shreck, TEI tax counsel, coordinated the preparation of TEI’s comments.
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