The Application of Revised Transfer Pricing Rules to Aspects of Business Models: Issues Identified by the Organisation for Economic Co-operation and Development and Solutions Proposed as Part of the Base Erosion and Profit Shifting Project

• Autores: Andrew Hickman
• Localización: Intertax, ISSN 0165-2826, Vol. 44, Nº. 10, 2016 (Ejemplar dedicado a: The impact of the BEPS project on business models), págs. 730-734
• Idioma: inglés
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• Resumen

  • The author discusses specific concerns about the efficacy of the application of transfer pricing rules to aspects of business models that have been addressed in the revisions to the Organisation for Economic Co-operation and Development (OECD) Transfer Pricing Guidelines contained in the 2015 base erosion and profit shifting (BEPS) Report, Aligning Transfer Pricing with Value Creation. Distinctions are made between business models and transfer pricing business models that risk constraining the business to convenient explanations. Transfer pricing business models involving transfer of contractual risk and of legal ownership of intangibles are examined. Finally, the author predicts interest in single entity cross-border business models and the need to develop consistent guidance on attribution of profits to permanent establishments.