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Transfer Pricing Times – October 2019

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In this edition of Transfer Pricing Times, we present the latest and most relevant transfer pricing issues and developments from around the globe.

In the “OECD Provides a Unified Approach Proposal for Profit Allocation” article, we discuss the OECD’s discussion draft detailing a ‘Unified Approach’ proposal for Pillar I of the OECD’s Program of Work focused on the tax challenges associated with the digitalization of the economy.

In the “France Issues Draft Guidance on New Digital Services Tax” article, we review the published draft guidance by the French General Directorate of Public Finance on the new Digital Services Tax.

In the “Treasury and IRS Remove Intercompany Debt Documentation Rules and Signal Intent to Streamline Debt Recharacterization Rules” article, we summarize two key announcements made by the IRS and Treasury on the Section 385 regulations which were first introduced in April of 2016.

In the “U.S. Department of the Treasury Releases Priority Guidance Plan” article, we discuss the recent release of the Treasury’s initial Priority Guidance Plan, including several international tax and transfer pricing-related projects near the top of the list.

In the “Philippines Releases Internal Guidelines for Transfer Pricing Audits” article, we review the Philippine Bureau of Internal Revenue’s issuance of Revenue Audit Memorandum Order No. 1-2019 to provide standardized audit procedures and techniques during transfer pricing audits.

Finally, in the “Draft Risk Assessment Framework for Offshore Drilling Units in Australia Released” article, we discuss the ATO issuing draft Practical Compliance Guideline 2019/D5 which addresses its transfer pricing compliance approach to non-resident owned mobile offshore drilling units operating in Australia.

We hope that you will find this and future issues of Duff & Phelps’ monthly transfer pricing newsletter informative and reliable.

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