BEPS Action 8
Assure that transfer pricing outcomes are in line with value creation: intangibles
Description of this action in OECD's Action Plan (July 2013)
Develop rules to prevent BEPS by moving intangibles among group members. This will involve: (i) adopting a broad and clearly delineated definition of intangibles; (ii) ensuring that profits associated with the transfer and use of intangibles are appropriately allocated in accordance with (rather than divorced from) value creation; (iii) developing transfer pricing rules or special measures for transfers of hard-to-value intangibles; and (iv) updating the guidance on cost contribution arrangements.
Expected output and deadline for this action in OECD's Action Plan (July 2013)
Expected output 1: Changes to the Transfer Pricing Guidelines and possibly to the Model Tax Convention
Deadline: September 2014
Expected output 2: 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
3 October 2014
19 September 2014
Slides from OECD Webcast: Presentation of 2014 Deliverables
16 September 2014
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