Unfinished BEPS business
Two BEPS outputs of huge significance for transfer pricing have been delivered in the previous 12 months in the form of published versions of the OECD Transfer Pricing Guidelines 2017 and the revised OECD Model Tax Convention, both of which incorporate the agreed BEPS changes. Application of the new Guidelines to pre-existing transfer pricing inquiries by some tax authorities, on the basis that they simply clarify the arm's length principle despite the more extensive changes they contain, is one of the immediate challenges for many businesses.
Global tax developments shift the focus away from BEPS
Although in recent years BEPS has been the main driver of change in transfer pricing practice for businesses and tax authorities, in the last 12 months other developments have played a major part in shaping perceptions and approaches to structuring.
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- Country-by-country Reporting Implementation Guide
- Global Tax Dispute Resolution Handbook
- Global Transfer Pricing Handbook
- EMEA Tax Transactions Gude
- European Inbound Tax Guide
- Holding Regimes Guide
- Global Real Estate Taxation Guide
- Resource materials from other Baker McKenzie Practice Groups