14 July 2016

OECD releases discussion drafts on profit splits, attribution of profits to permanent establishments and conforming amendments to OECD Chapter IX on business restructurings

The Organisation for Economic Co-operation and Development (OECD) released discussion drafts on July 4, on the revised guidance on profit splits (BEPS1 Actions 8-10) and attribution of profits to permanent establishments (BEPS Action 7). It also requested public review of the document containing conforming changes to Chapter IX (business restructurings) of the OECD Transfer Pricing Guidelines (TPG).

A Tax Alert prepared by EY Netherlands, and attached below, provides additional details.

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ATTACHMENT

Full text of Tax Alert 2016-1228

Document ID: 2016-1228