Proposed EU Transfer Pricing Directive - TEI Comments
On January 3, 2024, TEI submitted a comment letter to the European Commission regarding its proposal for a transfer pricing directive. TEI's comments focused on the need to coordinate certain of the proposed directive's term definitions with how those terms are defined in other multinational settings, clarification to how corresponding and compensating adjustments are handled, as well the need for coordination of the transfer pricing rules with VAT and Customs duties, among other things. TEI's comments were prepared under the aegis of its EMEA Direct Tax Committee. Benjamin R.
TEI Files Comments regarding the OECD Secretariat’s “Unified Approach” to Pillar One
On November 11, TEI submitted comments to the OECD Secretariat regarding its proposed “unified approach” to “Pillar One” of the tax challenges of the digitalization of the economy. TEI’s comments focused on the need for (i) the withdrawal of unilateral measures after a multilateral agreement, (ii) a multilateral dispute resolution mechanism; and (iii) reliance on taxpayer consolidated financial statements for purposes of the approach, among other subjects.
TEI Files Comments regarding the Platform for Collaboration on Tax’s Draft Transfer Pricing Toolkit
On November 7, TEI submitted comments to the Platform for Collaboration on Tax – a joint initiative of the World Bank, OECD, International Monetary Fund, and United Nations – regarding its draft transfer pricing documentation toolkit for developing countries.
TEI Submits Comments to the OECD regarding Digitalization of the Economy Consultation
On March 4th, TEI submitted comments to the OECD regarding its public consultation document entitled Addressing the Tax Challenges of the Digitalisation of the Economy. TEI will also participate in in the upcoming public consultation on March 13-14 in Paris.
TEI Submits Comments to the Treasury and IRS regarding Proposed Regulations under Section 965
On October 9th, TEI submitted comments to the Treasury and IRS regarding proposed regulations promulgated under the transition tax imposed by section 965, as amended by the Tax Cuts & Jobs Act enacted in 2017.
TEI Submits Comments to the OECD regarding the Transfer Pricing aspects of Financial Transactions
On September 6th, TEI submitted comments to the OECD regarding its public discussion draft under BEPS Actions 8-10 on the transfer pricing aspects of financial transactions.
TEI Comments on Scope of Revisions to OECD Transfer Pricing Guidelines
On June 19, TEI submitted comments to the OECD regarding the scope of future revisions to Chapters IV and VII of the OECD’s transfer pricing guidelines. TEI’s comments focused on the practical aspects of any future guidance.
TEI Comments on the European Commission’s Digital Economy Tax Proposals
On May 15, TEI submitted comments regarding the European Commission’s proposals to define the concept of a “significant digital presence” for corporate income tax purposes and impose an interim digital services tax.