Durst suggests changes to OECD guidance on transfer pricing for intangibles
In a Tax Notes viewpoint, international tax practitioner Michael C. Durst, who formerly served as director of the IRS advance pricing agreement program, offers suggestions for improving the OECD's proposed modifications to its transfer pricing guidance regarding the taxation of income from intangible property.

In the viewpoint, Durst addresses three issues:

  • "whether the OECD is correct that income-shifting transactions are inconsistent with the arm's-length principle";.
  • possible "changes to the OECD's proposed language that might prove helpful in realizing the proposal's apparent intent"; and
  • "the implications of the OECD's decision to pursue perceived improvements to international tax laws, even if implementing the OECD's proposed reforms might require changes to tax laws in some OECD member countries."

To read Durst's viewpoint, click here.
By Durst, Michael C., posted on Tuesday November 6, 2012
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