Strategizing International Tax Best Practices – by Keith Brockman

Posts tagged ‘ALP’

OECD Pillar I: Transform ALP

The Organisation for Economic Co-operation and Development (OECD) held a public consultation on the Secretariat Proposal for a “Unified Approach” under Pillar 1 of the BEPS 2.0 project on 21-22 November 2019 in Paris at the OECD Conference Centre.

The OECD Secretariat laid out the timeline for meetings of the Inclusive Framework for the end of January 2020 and in June/July 2020, and suggested that, at a minimum, a high-level political agreement on the Pillar One framework must be achieved by the January meeting.

One commonality voiced at the meeting was that the existing global transfer pricing system, based on the arm’s-length principle, needs to be changed and should at least be augmented by some more formulaic rules.

This common voice is expressed in terms of Pillar One re: digital tax, although this concept has also been trending for international tax in general.  It will be interesting to watch this development as the meetings address Pillar Two and a global minimum tax.

Videos of the meeting and other details can be referenced in the EY Global Tax Alert.

https://www.ey.com/Publication/vwLUAssets/Report_on_recent_US_international_tax_developments_-_27_November_2019/$FILE/2019G_005349-19Gbl_Report%20on%20recent%20US%20intl%20tax%20developments%20-%2027%20Nov%202019.pdf

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