International - The Profit Split Method: Status Quo and Outlook in Light of the BEPS Action Plan
- V. Chand; S. Wagh
- International Transfer Pricing Journal, 2014 (Volume 21), No 6
- 4 November 2014
The authors analyse whether the OECD’s base erosion and profit shifting (BEPS) project would increase the use of the profit split method. After reviewing the current landscape in this context, the authors focus on situations in which the profit split method applies, the various approaches that can be used to split the profit among associated enterprises and reasons why the profit split method has been infrequently applied. Finally, the authors present their views on the application of the profit split method in light of the BEPS Action Plan.