On January 13, 2015, TEI submitted comments to the OECD on its Public Discussion Draft regarding BEPS Action 10: Proposed Modifications to Chapter VII of the Transfer Pricing Guidelines Relating to Low Value-Adding Intra-Group Services. TEI commended the OECD for its approach in the Discussion Draft as a welcome simplification to transfer pricing rules for intra-group services. TEI’s recommendations included providing additional details and clarification in certain areas, such as allocation of senior management services and employee time, as well as shareholder and stewardship services.
TEI’s comments were prepared under the aegis of TEI’s European Direct Tax Committee, whose chair is Nick Hasenoehrl. Benjamin R. Shreck, TEI Tax Counsel, coordinated the preparation of TEI’s comments.