By Mayur B. Nayak | Tarun Kumar G. Singhal | Anil D. Doshi | Mahesh G. Nayak
Chartered Accountants
In the past six months, many developments have taken place in the International Tax arena relating to Transfer Pricing, Pillar I and Pillar II of the BEPS Project and proposed introduction of corporate tax in UAE etc.
In this article, we have covered some of these developments for updating the readers.
1. OECD RELEASES THE LATEST EDITION OF THE TRANSFER PRICING GUIDELINES FOR MULTINATIONAL ENTERPRISES AND TAX ADMINISTRATIONS
On 20th January, 2022, the OECD released the 2022 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.
The
OECD Transfer Pricing Guidelines provide guidance on the application of the “arm’s length principle”, which represents the international consensus on the valuation, for income tax purposes, of cross-border transactions between associated enterprises. In today’s economy, where multinational enterprises play an increasingly prominent role, transfer pricing continues to be high on the agenda of tax administrations and taxpayers alike. Governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdiction and that the tax base reported by MNEs in their country reflects the economic activity undertaken therein and taxpayers need clear guidance on the proper application of the arm’s length principle.
This latest edition consolidates in
