BorderCrossings ... with Ernst & Young's transfer pricing and tax professionals
OECD Discussion Draft: Transfer pricing aspects of intangibles
To help you stay informed and able to adapt to an increasingly uncertain and challenging global tax environment, Ernst & Young is pleased to bring you this fifteenth installment of BorderCrossings – our monthly webcast series devoted to transfer pricing and related tax issues. Following on the heels of our May program that focused on the 15 March 2012 release of the updated UN Model Tax convention, the second season of our BorderCrossings series continues this month with another timely program – on the much anticipated 6 June 2012 release of the OECD's discussion draft on the transfer pricing aspects of intangibles.
OECD Working Party No. 6 releases discussion draft on the transfer pricing aspects of intangibles
Appropriate transfer pricing treatment of intangibles presents particular conceptual and practical challenges in comparison to the treatment of physical or financial assets. Accordingly, in 2010 the OECD announced the commencement of a project to address such challenges. During consultations held since that time, the business community suggested it would be helpful if the OECD were to periodically release a discussion draft for public comment as its work progresses.
Such a document, prepared by the OECD's Working Party No. 6, was released for comment on 6 June 2012. It contains proposed revisions to Chapter VI of the OECD Transfer Pricing Guidelines, as well as annexed examples illustrating the application of the provisions of the proposed revised Chapter.
While the OECD's Committee on Fiscal Affairs has not yet considered the draft, and the draft does not address all the topics that will eventually be covered, the scope of this initial draft paper is very comprehensive. This webcast will address issues such as:
- What may be considered an intangible for transfer pricing purposes?
- May more than one entity be entitled to the return from an intangible?
- When might it be appropriate to use an alternative to the five recognized OECD methods?
During this live, interactive webcast, you will have the opportunity to ask questions through the website and the panelists will answer as many of your questions as time permits.
This program will be of interest to vice presidents/directors of tax/international tax/transfer pricing, directors of finance, CFOs, international tax managers and tax accountants looking for the latest practical information and guidance to support their global business initiatives. We are extremely pleased to announce the participation of the Chair of OECD Working Party No. 6 as our lead panelist. We hope you will be able to join us!
, Chair, OECD Working Party No. 6
, Ernst & Young LLP (US), Transfer Pricing
, Ernst & Young LLP (Canada), Transfer Pricing
Fred O’Riordan, Ernst & Young LLP (Canada), National Advisor, Tax Services
Save the date for the next BorderCrossings webcast:
1:00–2:15 p.m. EDT New York/Toronto; 10:00–11:15 a.m. PDT Los Angeles/Vancouver