Read the latest Tax Alert on the "Update: OECD Transfer Pricing Simplification Rules" 👉 https://lnkd.in/dVnjMc5d #KPMGTaxandLegal #TaxAlert
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IRS Plans Proposed Regulations Applying Foreign Tax Credit and Dual Consolidated Losses to GloBE Rules, Extends Relief. The IRS and Treasury have announced in Notice 2023-80 that they intend to issue proposed regulations to address the application of certain provisions to taxes described in the OECD Tax Challenges Arising from the Digitalisation of the Economy—Global Anti-Base Erosion Model Rules (Pillar Two) ("GloBE Model Rules"). The proposed regulations are expected to be consistent with the guidance in the notice. #oecd #globalminimumtax #pillar2 #irs #treasury https://lnkd.in/e9JiyJ8S
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#17 June 2024# OECD released supplementary elements relating to the report on Amount B of Pillar One and guidance to ensure consistent implementation and application of the global minimum tax under Pillar Two. Below is Pillar Two Administrative Guidance Update link: https://lnkd.in/gc_Kpr67 #Pillar One Amount B Link: https://lnkd.in/gWgzGv5T
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[#LetsTalkGlobalTax] The financial services sector faces intense scrutiny from global tax authorities and regulators. Transfer pricing documentation is crucial for accurate taxes and compliance with recent OECD reforms and HMRC proposals. Please see the below insight from me based on what we are seeing in the sector: https://lnkd.in/edQYDRC9
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[OUT NOW] Pillar One - Amount B In October 2021, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting agreed to simplify and streamline the application of the arm’s length principle to in-country baseline marketing and distribution activities. This new report provides a simplified approach and guidance for the application of the arm’s length principle at jurisdiction level. The report is accompanied by conforming changes to the Commentary on Article 25 of the OECD Model Tax Convention. The simplified approach is expected to reduce transfer pricing disputes, compliance costs, and enhance tax certainty for tax administrations and taxpayers alike, particularly across low-capacity jurisdictions. Content from the report has now been incorporated into the OECD Transfer Pricing Guidelines. 📚 Access the report and the Reader's Guide ➡️ https://oe.cd/5qm 🗞️ Read the web announcement ➡️ https://oe.cd/5qk #OECDtax #OECD #tax #OECDP1 #Pillar1 #internationaltax #taxreform #AmountB #TrustinTax #TaxCertainty #TransferPricing #BEPS
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Global Tax Manager – Group Transfer Pricing | International Tax Author & Correspondent (Opinions are my own)
Amount B released and incorporated into the OECD TP Guidelines. Option to apply it for countries starting 2025. Significant reservations from India included in the report. To be confirmed by reality the following statements "Nothing in the guidance contained in this report should be construed as a basis to interpret the application of the general principles in the remainder of the OECD Transfer Pricing Guidelines with respect to any transactions, nor should this guidance be interpreted as revising those principles". [...] "The fact that an activity does not qualify for the simplified and streamlined approach under this guidance should not be interpreted to mean that such activity generates lower or higher returns than is permissible under the simplified and streamlined approach or that the returns applied for in-scope taxpayers represents a “floor” or a “ceiling” for returns to distribution activities in general."
[OUT NOW] Pillar One - Amount B In October 2021, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting agreed to simplify and streamline the application of the arm’s length principle to in-country baseline marketing and distribution activities. This new report provides a simplified approach and guidance for the application of the arm’s length principle at jurisdiction level. The report is accompanied by conforming changes to the Commentary on Article 25 of the OECD Model Tax Convention. The simplified approach is expected to reduce transfer pricing disputes, compliance costs, and enhance tax certainty for tax administrations and taxpayers alike, particularly across low-capacity jurisdictions. Content from the report has now been incorporated into the OECD Transfer Pricing Guidelines. 📚 Access the report and the Reader's Guide ➡️ https://oe.cd/5qm 🗞️ Read the web announcement ➡️ https://oe.cd/5qk #OECDtax #OECD #tax #OECDP1 #Pillar1 #internationaltax #taxreform #AmountB #TrustinTax #TaxCertainty #TransferPricing #BEPS
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Global Tax Leader | Tax Manager | Tax Planning | International Tax | Transfer Pricing
Today, the OECD released the report on Amount B of Pillar One. The new report provides a simplified and streamlined approach to apply the arm’s length principle to baseline marketing and distribution activities at country-jurisdiction level, and is expected to reduce transfer pricing disputes and compliance costs, and, consequently, increase tax certainty for taxpayers especially in low-capacity jurisdictions. The report is accompanied by conforming changes to the Commentary on Article 25 of the OECD Model Tax Convention, and the content has been incorporated into the OECD Transfer Pricing Guidelines. To access the full content, check below the OECD publication:
[OUT NOW] Pillar One - Amount B In October 2021, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting agreed to simplify and streamline the application of the arm’s length principle to in-country baseline marketing and distribution activities. This new report provides a simplified approach and guidance for the application of the arm’s length principle at jurisdiction level. The report is accompanied by conforming changes to the Commentary on Article 25 of the OECD Model Tax Convention. The simplified approach is expected to reduce transfer pricing disputes, compliance costs, and enhance tax certainty for tax administrations and taxpayers alike, particularly across low-capacity jurisdictions. Content from the report has now been incorporated into the OECD Transfer Pricing Guidelines. 📚 Access the report and the Reader's Guide ➡️ https://oe.cd/5qm 🗞️ Read the web announcement ➡️ https://oe.cd/5qk #OECDtax #OECD #tax #OECDP1 #Pillar1 #internationaltax #taxreform #AmountB #TrustinTax #TaxCertainty #TransferPricing #BEPS
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A good summary by Soph on the OECD Part B announcement. More details to come!
[OUT NOW] Pillar One - Amount B In October 2021, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting agreed to simplify and streamline the application of the arm’s length principle to in-country baseline marketing and distribution activities. This new report provides a simplified approach and guidance for the application of the arm’s length principle at jurisdiction level. The report is accompanied by conforming changes to the Commentary on Article 25 of the OECD Model Tax Convention. The simplified approach is expected to reduce transfer pricing disputes, compliance costs, and enhance tax certainty for tax administrations and taxpayers alike, particularly across low-capacity jurisdictions. Content from the report has now been incorporated into the OECD Transfer Pricing Guidelines. 📚 Access the report and the Reader's Guide ➡️ https://oe.cd/5qm 🗞️ Read the web announcement ➡️ https://oe.cd/5qk #OECDtax #OECD #tax #OECDP1 #Pillar1 #internationaltax #taxreform #AmountB #TrustinTax #TaxCertainty #TransferPricing #BEPS
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Transfer Pricing Senior Analyst | CA member of Indonesia for MAP & APA Asia-Pacific & Middle East Region | Adv. LLM International Tax Law | APCIT & APCTP (IBFD) | Indonesia's Delegate in G20/OECD TFDE & FTA MAP
One of the three components of Pillar One has finally arrived.
In October 2021, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting agreed to simplify and streamline the application of the arm’s length principle to in-country baseline marketing and distribution activities. Under this mandate, the OECD has launched today’s report on Amount B of Pillar One, which provides a simplified approach for the application of the arm’s length principle at country jurisdiction-level. The report is accompanied by conforming changes to the Commentary on Article 25 of the OECD Model Tax Convention. The simplified and streamlined approach presented in the report is expected to reduce transfer pricing disputes, compliance costs, and enhance tax certainty for tax administrations and taxpayers alike, particularly across low-capacity jurisdictions. Content from the report has now been incorporated into the OECD Transfer Pricing Guidelines. 📚 Access the report and the Reader’s Guide ➡️ http://oe.cd/5qm 🗞️ Read the web announcement ➡️ http://oe.cd/5qk #OECDtax #OECD #tax #OECDP1 #Pillar1 #internationaltax #taxreform #AmountB #TrustinTax #TaxCertainty #TransferPricing #BEPS
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Director Transfer Pricing bei PwC Deutschland | Diplom-Volkswirt | Wein- und Cognac-Enthusiast
"On 19 February 2024, the OECD/G20 Inclusive Framework on BEPS released the report on Amount B of Pillar One, which provides a simplified and streamlined approach to the application of the arm's length principle to baseline marketing and distribution activities, with a particular focus on the needs of low-capacity countries. The approach set out in this report answers the call of low-capacity countries for what the African Tax Administration Forum (ATAF) has described as "vital" changes to the OECD Transfer Pricing Guidelines, providing what "could be a game changer for the African transfer pricing landscape". Content from the report has now been incorporated into the OECD Transfer Pricing Guidelines." #transferpricing #tax #amountb
[OUT NOW] Pillar One - Amount B In October 2021, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting agreed to simplify and streamline the application of the arm’s length principle to in-country baseline marketing and distribution activities. This new report provides a simplified approach and guidance for the application of the arm’s length principle at jurisdiction level. The report is accompanied by conforming changes to the Commentary on Article 25 of the OECD Model Tax Convention. The simplified approach is expected to reduce transfer pricing disputes, compliance costs, and enhance tax certainty for tax administrations and taxpayers alike, particularly across low-capacity jurisdictions. Content from the report has now been incorporated into the OECD Transfer Pricing Guidelines. 📚 Access the report and the Reader's Guide ➡️ https://oe.cd/5qm 🗞️ Read the web announcement ➡️ https://oe.cd/5qk #OECDtax #OECD #tax #OECDP1 #Pillar1 #internationaltax #taxreform #AmountB #TrustinTax #TaxCertainty #TransferPricing #BEPS
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There’s fresh news in the TP world! The report on Amount B was published today. It will be incorporated in an annex to the OECD TPGs. The implementation of Amount B should provide benefits to taxpayers and tax administrations (especially in low capacity jurisdictions) in the context of baseline marketing and distribution activities.
[OUT NOW] Pillar One - Amount B In October 2021, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting agreed to simplify and streamline the application of the arm’s length principle to in-country baseline marketing and distribution activities. This new report provides a simplified approach and guidance for the application of the arm’s length principle at jurisdiction level. The report is accompanied by conforming changes to the Commentary on Article 25 of the OECD Model Tax Convention. The simplified approach is expected to reduce transfer pricing disputes, compliance costs, and enhance tax certainty for tax administrations and taxpayers alike, particularly across low-capacity jurisdictions. Content from the report has now been incorporated into the OECD Transfer Pricing Guidelines. 📚 Access the report and the Reader's Guide ➡️ https://oe.cd/5qm 🗞️ Read the web announcement ➡️ https://oe.cd/5qk #OECDtax #OECD #tax #OECDP1 #Pillar1 #internationaltax #taxreform #AmountB #TrustinTax #TaxCertainty #TransferPricing #BEPS
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Manager at KPMG Tax & Advisory
1wThanks for sharing. It is very insightful