KPMG Report: Insights on OECD's Revised "Unified Approach" to Tax Challenges of Digitalisation
The Organisation for Economic Cooperation and Development (OECD) on January 31, 2020, issued a statement (the Statement) by the OECD/G20 Inclusive Framework on BEPS, reaffirming its commitment to reach a consensus-based long-term solution to the tax challenges arising from the digitalisation of the economy and stating that the Inclusive Framework will continue following a two-pillar approach in working toward an agreement by the end of 2020. The Statement is also accompanied by an updated Programme of Work setting out the timeline for the work on Pillar One and the remaining technical challenges to be addressed. The Inclusive Framework also stated its expectation that any consensus-based solution would need to include a commitment by members to implement the solution and withdraw relevant unilateral measures. This report provides KPMG observations on the Pillar One work.
KPMG Report: OECD Transfer Pricing (Final) Guidance on Financial Transactions: Initial Impressions
As part the base erosion and profit shifting (BEPS) project, Actions 8-10, the Organisation for Economic Cooperation and Development (OECD) on February 11, 2020, issued final recommendations regarding the arm’s-length treatment of various financial transactions among related parties. This follows release of proposed guidance in July 2018 and applies transfer pricing methods to intercompany loans, cash pools, financial guarantees, hedging transactions, and captive insurers. This report provides KPMG initial impressions and observations, including notes about changes from the 2018 draft.
Global Glare: International Tax Reform Steals the Spotight
This issue of CTO Insights discusses how CTOs in companies across America are increasingly focused on global tax reform and the OECD's efforts to develop a unified approach to address the challenges presented by the impact and influence of the digital economy.
INSIGHT: Taxing the Digital Economy – As Simple as "A, B, C"?
KPMG professionals examine the OECD Secretariat's October 9 proposal under Pillar One, on the allocation of taxing rights and profits, of the Inclusive Framework. Article appeared in October 21, 2019 issue of Daily Tax Report (Bloomberg Tax).
INSIGHT: Cost-Plus Transfer Pricing for Marketing Support Services between BEPS 1.0 and BEPS 2.0
KPMG LLP collected feedback from 26 KPMG International member firms to understand the extent to which a cost-plus transfer pricing remuneration for marketing support services would be challenged in today's environment form a local transfer pricing perspective.