Dbriefs Webcast

Special edition | Hard to value intangibles: What does new BEPS guidance portend?

Transfer Pricing

August 22 | 11 a.m. ET | 15:00 GMT

Host: Mark Nehoray, partner, Deloitte Tax LLP
1.5 Overview CPE credits | Taxes

In June the OECD released a discussion draft of BEPS Action 8 Implementation Guidance on Hard-to-Value Intangibles (HTVI). What revisions are being proposed in the transactional profit split and attribution of profit to permanent establishment drafts? We'll discuss:

  • The process leading to issuance of these drafts and the remaining areas of disagreement between countries regarding Actions 8-10.
  • How the disagreements are reflected in the HTVI and profit split draft and challenges associated with the attribution of profit draft.
  • Potential paths the OECD might take from here to finalize the BEPS Actions 8-10 mandate.

Participants will learn about the proposed guidance and how profits should be shared under the profit split method.