The Evolution of the Profit Split Analysis

Location The Shard, 32 London Bridge Street

London SE1 9SG

Calendar November 21, 2019

Duff & Phelps' Transfer Pricing team invite you to join their second seminar in the Autumn Transfer Pricing Series.
A year has passed since the OECD issued its revised guidance on the application of the profit split method in the context of global value chains, and profit split is increasingly finding favor with the OECD and tax administrations as a solution for challenging profit-allocation situations. A formulary profit split approach has been proposed by the OECD Secretariat to recognize more market profits in the ongoing taxation of the digitalized economy debate.

On November 21, the OECD will host a public meeting to discuss a “Unified Approach” under Pillar One of the work program. Meanwhile, taxpayer experience indicates that HMRC is displaying a clear preference for the application of profit split analysis in its advance pricing agreement (APA) negotiations.

Register now.

Topics will include:

  • Changes to the OECD Guidelines on profit split introduced by BEPS Actions 8-10
  • Preference for “two-sided” profit split approaches to transfer pricing over other methods, such as TNMM and CUP
  • The role of profit split analysis in “hard to value intangibles”
  • Applications: profit split and post-merger integration transfer pricing
  • The application of profit split in the OECD Secretariat’s proposed Pillar One “Unified Approach”


  • 8:30 a.m. - 9:00 a.m. – Registration and breakfast
  • 9:00 a.m.- 10:30 a.m. – Seminar

 Time slots mentioned above are in GMT.

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