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Friday, June 3, 2011
How do governments fairly assess taxes on a multinational company's cross-border transactions involving highly valuable intangibles for which no third-party comparables exist? U.S. and Canadian government officials will provide their views on this topic in the context of recent changes to the Organization for Economic Cooperation and Development's transfer pricing guidelines. The webinar will begin at 11 a.m. on Oct. 13.
During the 90-minute presentation, David Ernick, the U.S. Treasury Department's international tax counsel, and Michelle Levac, transfer pricing specialist for the Canada Revenue Agency's international tax division, will explain how their governments interpret recent changes to the OECD's Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, which advocate using unrelated-party transactions as a benchmark for the pricing of goods and services between related parties.
Among the issues discussed will be a controversial provision that some believe will allow revenue authorities to disregard business restructurings that are not "commercially rational," as well as the OECD's next project on defining valuable intangibles and determining where they should be taxed in the absence of "real world" transactions between unaffiliated companies.
Register for the webinar at http://www.bnatax.com/oecd-transfer-pricing-webinar/
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