BEPS Action 10
Assure that transfer pricing outcomes are in line with value creation: other high-risk transactions
Description of this action in OECD's Action Plan (July 2013)
Develop rules to prevent BEPS by engaging in transactions which would not, or would only very rarely, occur between third parties. This will involve adopting transfer pricing rules or special measures to : (i) clarify the circumstances in which transactions can be recharacterized; (ii) clarify the application of transfer pricing methods, in particular profit splits, in the context of global value chains; and (iii) provide protection against common types of base eroding payments, such as management fees and head office expenses.
Expected output and deadline for this action in OECD's Action Plan (July 2013)
Expected output : Changes to the Transfer Pricing Guidelines and possibly to the Model Tax Convention
Deadline : September 2015
OECD: Public comments received on BEPS Actions 8-10 discussion draft: revisions to Chapter I of the Transfer Pricing Guidelines (Including risk, recharacterisation and special measures)
10 February 2015
14 November 2014
Release of discussion draft on Action 10 of the BEPS Action Plan
3 November 2014
10 October 2014
3 October 2014
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