Rocco Femia Quoted Regarding Recent BEPS Drafts on Transfer Pricing in Tax Notes Today

"BEPS Presents Slippery Slope Toward Formulary Apportionment"
Tax Notes Today
02.12.15Rocco Femia was quoted regarding the recent OECD BEPS discussion drafts on transfer pricing released under Actions 8, 9 and 10. Femia noted that these drafts could result in the allocation of profits to service providers beyond a cost-plus fee. "I think that notwithstanding all of the cautions from U.S. Treasury and other officials that this is not about fundamentally changing the allocation of income between source country and residence country, it is an inevitable result of what is being discussed," he said.
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