The OECD’s Base Erosion and Profit Shifting (BEPS) project deals, among others, with aggressive transfer pricing by Multinational Enterprises, whereby the profitability of subsidiaries in different jurisdictions is “adjusted” via misplacing, with the intent of minimizing the corporation’s overall tax burden. Although the OECD BEPS project is an ongoing endeavor, its accomplishments to date and developing trends are discernible. This chapter of the book is dedicated to the analysis of the low value-adding services as defined in OECD BEPS Action 10.
Maisto, G., Transfer pricing aspects of low value-adding services, in Lang, M., Storck, A., Petruzzi, R. (ed.), Transfer pricing in a post-BEPS World, Wolters Kluwer, Alphen aan den Rijn 2016: 145- 158 [http://hdl.handle.net/10807/95578]
Transfer pricing aspects of low value-adding services
Maisto, Guglielmo
2016
Abstract
The OECD’s Base Erosion and Profit Shifting (BEPS) project deals, among others, with aggressive transfer pricing by Multinational Enterprises, whereby the profitability of subsidiaries in different jurisdictions is “adjusted” via misplacing, with the intent of minimizing the corporation’s overall tax burden. Although the OECD BEPS project is an ongoing endeavor, its accomplishments to date and developing trends are discernible. This chapter of the book is dedicated to the analysis of the low value-adding services as defined in OECD BEPS Action 10.
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