Last week, Copenhagen Economics submitted our comments to the OECD’s Public Discussion Draft on the Profit Split Method.
In the comment, we point out that the discussion draft does not provide taxpayers and tax administrations with a thorough and univocal guidance on when and how to apply the profit split method.
Rather, we believe that some paragraphs could create confusion and lead to a misuse of the method.
Our concerns relate to three overall issues:
- The proposed hierarchies are not based on sound business arguments
- The discussion draft should clarify the key concepts underpinning the profit split method
- The discussion draft should make technical clarifications with respect to the economic ownership of intangibles and the use of segregated vs. total profits
For further information, please contact Hendrik Fügemann