The European Direct Tax Committee covers income-based tax aspects of European operations, including tax treaty matters, and develops the Institute’s positions and submissions to taxing authorities in European countries, as well as the European Union and OECD.
TEI Comments on OECD Request Regarding the Digitalization of the Economy
TEI Comments on OECD Discussion Draft Regarding Revised Profit Split Guidance
TEI Comments on OECD Hard-to-Value-Intangibles Draft
TEI Participates in IRS Country-by-Country Association Roundtable
On January 12, 2017, TEI Executive Director Eli Dicker and Tax Counsel Benjamin Shreck participated in a roundtable discussion of the IRS’s administration of country-by-country (CbC) reporting. The discussion focused on the CbC forms, instructions and guidance, external communication and outreach, compliance and enforcement issues, as well as international exchange and use of CbC information.
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.
TEI Comments on OECD PE Profit Attribution Draft
On September 2, 2016, Tax Executives Institute, Inc., submitted a letter to the OECD commenting on its July 4 public discussion draft regarding Additional Guidance on the Attribution of Profits to Permanent Establishments. The discussion draft consists of follow up guidance under Action 7 of the OECD’s base erosion and profit shifting (better known as BEPS) project.
TEI Comments on BEPS Multilateral Instrument
On June 29, 2016, TEI filed a comment letter with the OECD regarding its request for input on Development of a Multilateral Instrument to Implement the Tax Treaty related BEPS Measures under Action 15 of the OECD’s base erosion and profit shifting (BEPS) project.
TEI Comments on Proposed UK Tax Strategy Publication Requirement
On February 2, 2016, Tax Executives Institute submitted comments with HM Revenue & Customs, the revenue authority in the United Kingdom, regarding a proposal in the UK government's Finance Bill 2016 to require certain large businesses with UK operations to publish a UK tax strategy. The Institute's comments recommend clarifying the definition of a "UK sub-group" and how multinational businesses that are not headquartered in the United Kingdom can comply with the publication requirement.
TEI Comments on EC Common Consolidated Corporate Tax Base Consultation
On January 7, 2016, Tax Executives Institute filed comments with the European Commission regarding the Commission's "re-launch" of its common consolidated corporate tax base (CCCTB) proposal.