BEPS Implementation and Transfer Pricing - …

12/2/20161 beps Implementation and Transfer PricingGWU IRS 29thAnnual Institute on Current Issues in International TaxationDecember 15, 2016 Washington, DC1 Chris Bello, Chief, Branch 6, ACC(I), IRS John Hughes, Acting Director, APMA, IRS Michael McDonald, Financial Economist, Treasury Dept. Rocco Femia, Member, Miller & Chevalier Barbara Rollinson, Managing Director, Horst Frisch Bill Sample, Vice President Tax, Microsoft Attribution of profits to PEs profit splits Post beps Local Country Developments Legal developments Administration and enforcement Other Pending Items Hard to value intangibles Low value services 3 Attribution of Profits412/2/20163 Introduction Report on beps Action 7 (Preventing the Artificial Avoidance of PE Standard) recommended lowering of PE standard Expansion of dependent agent PE concept Narrowing of specific activity exceptions Anti fragmentation rule Report also concluded that additional guidance was needed as to the application of the Article 7 attribution of profits rules to PEs resulting from changes in the Report Discussion Draft issued for public comment on July 4, 2016 Public Consultations held October 11, 2016 5 Attribution

12/2/2016 2 Agenda •Attribution of Profits to PEs •Profit Splits •Post‐BEPS Local Country Developments –Legal developments –Administration and enforcement

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  Implementation, Transfer, Split, Profits, Pricing, Beps, Beps implementation and transfer pricing, Profit splits

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