Comments on the OECD's Public Discussion Draft BEPS Actions 8-10, 'Revised Guidance on Profit Splits', Issued on 4 July 2016
4 Pages Posted: 2 Jan 2020
Date Written: September 5, 2016
Abstract
Commentary submitted to the OECD on the OECD's Discussion Draft on BEPS Action Items 8-10 - Guidance on Profit Splits. My comments focus on value chains and value chain analysis, allocation keys in profit splits, and problems inherent in the method of calculating the residual profit split method.
Keywords: transfer pricing, OECD, profit split method, BEPS, allocation key, value chain, international tax
JEL Classification: F23, H25, H26, K34, K420, K330, L11
Suggested Citation: Suggested Citation
Eden, Lorraine, Comments on the OECD's Public Discussion Draft BEPS Actions 8-10, 'Revised Guidance on Profit Splits', Issued on 4 July 2016 (September 5, 2016). Available at SSRN: https://ssrn.com/abstract=3500572 or http://dx.doi.org/10.2139/ssrn.3500572
Do you have negative results from your research you’d like to share?
Feedback
Feedback to SSRN
If you need immediate assistance, call 877-SSRNHelp (877 777 6435) in the United States, or +1 212 448 2500 outside of the United States, 8:30AM to 6:00PM U.S. Eastern, Monday - Friday.