TP Lecture week 14 – Intra-group services Part II
Follow curriculum – Reading:
OECD TPG Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration July 2017
Chapter VII
| Action 10 Low value-adding intra-group servicesFOR MORE INSIGHT ON INTRA-GROUP SERVICES, PLEASE READ THIS ARTICLE: Intra-Group Services: Guidelines, Examples, and Risk Management Strategies Intra-Group Services refer to activities performed by one entity within a multinational enterprise (MNE) group that benefit one or more associated enterprises. These services may include administrative, technical, financial, or commercial assistance provided by a central company to its affiliates. A primary..., page 141 |
| BEPSBEPS stands for "Base Erosion and Profit Shifting". BEPS refers to tax avoidance strategies used by multinational enterprises (MNEs) to exploit gaps and mismatches in the international tax system. By shifting profits from high-tax jurisdictions to low- or no-tax locations, MNEs reduce their overall tax burden, even if little to no economic activity occurs in the low-tax jurisdictions. These practices erode... Actions 8-10 Final Report |
| Intangibles, Risks & Capital, High-Risk Transactions |
| http://www.oecd.org/ctp/beps-actions.htm |
BEPS Action 10 – Transfer Pricing_ Other High Risk Transactions _ Rödl & Partner
General ongoing reading as the courses advance, reading about 10 pages a week to gain an overview understanding: An Overview of Transfer Pricing by IBFD
Start your Assignment 3 preparation now – start reading the EXTENSIVE DOCUMENTS: the pre-trial filing of Coca-cola to the US tax court, and the long list of supporting articles, and start summarizing the case using the principles in 1 Reading cases SSRN-id1160925 This may appear as a key exam question as well.
The coca-cola case pre-trial document and articles can be found here: http://iitfconnect.com/?p=675
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