The OECD has been debating the most appropriate way to determine the arm’s length price for intangible property. Compare and contrast the OECD BEPS project guidelines for determining the arm’s length price of intangibles with those of the U.S. regulations (§1.482-4 and §1.482-7).
1. Explain the implications of adopting a different standard.
2. How does the OECD guidance on DEMPE to reward intangible property transactions compare to the U.S. IRC section 482 and the corresponding U.S. regulations on the pricing of Intangible property?
3. BEPS 2.0, Pilar 1 Amount B – What are the transfer pricing implications? How would one determine the appropriate return given the diversity of different companies.
4. BEPS 2.0, Pilar 2 – what are the transfer pricing implications?
5. Tax authorities are in the process of adopting BEPS 2.0 Pillar 2. Within Pillar 2.0, a multinational’s earnings will be ‘allocated’ among each country where the company operates.
6. Any other topic which interests you
7. Does Pillar 2 mean the arm’s length standard is dead? …or can the two tax standards co-exist?
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