Oxford University Centre for Business Taxation
The Future of the Arm’s Length Principle conference
The Oxford University Centre for Business Taxation hosted this conference discussing the important topic of 'The Future of the Arm's Length Principle'.
Significant reforms to the arm’s length principle (ALP) were identified as a major priority for the OECD’s recent Base erosion and profit shifting (BEPS) project. In consequence, the BEPS output includes a raft of new transfer pricing measures intended to counter avoidance activity relating to income allocation within a multinational group. BEPS also introduced an increased focus generally on substance and transparency, and, in the process of reform, triggered a material hike in the complexity of applying the arm's length principle.
Against this background, this conference explored what it means to apply the transfer pricing (TP) and permanent establishment (PE) attribution rules in the aftermath of BEPS, and also considered future directions for reform. The discussion of future options for the arm's length principle included those areas on which the OECD is planning to focus as well as other areas which are arguably high priorities for reform if the principle is to remain viable.
The OECD’s new head of transfer pricing, Tomas Balco, spoke about the OECD’s work and priorities. Richard Collier, Associate Fellow of the Centre for Business Taxation, presented the conclusions from his new book co-authored with Joe Andrus and published by Oxford University Press, Transfer Pricing and the Arm's Length Principle After BEPS.* Other speakers included Louise Sykes, Head of Transfer Pricing at XL Catlin; Matt Hardy, Tax Director for Africa and Asia at Diageo; and Michael Devereux, Director of the CBT.
The conference was followed by a drinks reception at 5.30pm.
*Oxford University Press is offering a 20% discount on this title if purchased online at www.oup.com/uk/law - to claim your discount quote ALFLY5F.
|15:00 - 15:30||Registration|
Welcome and introduction followed by
Louise Sykes, SVP, Head of Transfer Pricing, XL Catlin
Issues from the Current Position
Matthew Hardy, Tax Director for Africa and Asia, Diageo
Likely Future Developments
Tomas Balco, Head of Transfer Pricing, OECD
The OECD view and work in progress on the ALP
Richard Collier, Associate Fellow, Saïd Business School, University of Oxford
Assessment of the ALP and priorities for the future
Michael Devereux, Director, Oxford University Centre for Business Taxation
More radical options to adapt or replace the ALP