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Safe harbor on low value added services, an option to emerging economies?
One of the novelties resulting from the OECD/G20 action plan vs. base erosion and profit shifting (the BEPS plan) is the suggestion of a safe harbor in relation to low value-added intercompany services. Said safe harbor, under certain limitations, would enable the transfer of certain types of support services (not associated in any way to
BEPS plan Action 13. Country by country report and transfer pricing documentation
New transfer pricing documentation standard One of the most visible actions of the BEPS plan is Action 13 (country by country report and transfer pricing documentation). Action 13 has taken effect, modifying Chapter V of the OECD Transfer Pricing Guidelines (OECD Guidelines) of 2017, and in Mexico, by incorporating article 76-A to the Mexican Income
Intangibles: New BEPS Guidelines
Intangibles: New BEPS Guidelines One of the main concerns of the OECD regarding the mechanisms of base erosion employed by taxpayers has to do with the use of intangibles, in particular regarding the distortion of their value in controlled transactions, or even their strategic allocation in preferential regimes, without considerations of transfer pricing rules that
General considerations for the BEPS plan
What is the BEPS plan?* The BEPS plan (acronym for action plan vs. base erosion and profit shifting) is a response by the G-20 to the aggressive tax practices implemented by some multinational taxpayers in recent years. The BEPS plan is coordinated by the Organization for the Economic Co-operation and Development (OECD) and seeks to
