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

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