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Associate Director Dr. Vladimir Starkov addressed the Organisation for Economic Co-operation and Development (OECD) at its two-day Public Consultation on Transfer Pricing, held on 6 and 7 November 2017 in Paris. The event addressed two OECD discussion drafts concerning revised guidance on profit splits and attribution of profits to permanent establishments.

Dr. Starkov was asked to provide commentary on implementation of the profit split method (PSM) and making adjustments to the profit split factors. His remarks to the OECD encompassed several points, including:

  • Reliable ways to measure relative contributions of valuable intangibles by multiple related parties when the contributions are not directly comparable;
  • What combinations of circumstances may warrant an adjustment for  Purchasing Power Parity (PPP);
  • What conditions should be met for the PSM to be the best applicable method for controlled transactions.

For more information, please visit the OECD website.