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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

Related material

BEPS ACTION 8: REVISIONS TO CHAPTER VIII OF THE TRANSFER PRICING GUIDELINES ON COST CONTRIBUTION ARRANGEMENTS
29 May 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

OECD: Actions 8-10: discussion draft on "low value-adding intra-group services"
20 January 2015

BEPS Actions 8, 9, and 10: Discussion draft on revisions to Chapter I of the Transfer Pricing Guidelines (including risk, recharacterisation, and special measures)
19 December 2014

Dbriefs Asia Pacific Webcast: BEPS Actions 8 and 13 (Transfer Pricing): Implications for the Financial Services Industry
14 October 2014

Dbriefs Bytes
10 October2014

Dbriefs Bytes
3 October 2014

Dbriefs Asia Pacific Webcast: OECD / G20 Transfer Pricing Documentation and Intangible Guidance
29 September 2014

Deloitte Transfer Pricing Alert: OECD Release on Intangibles: Many Issues Unanswered
19 September 2014

Dbriefs Bytes
19 September 2014

Deloitte Transfer Pricing Alert: OECD Chapter I Release: Important Guidance on Location-Specific Advantages and Passive Association
18 September 2014

Slides from OECD Webcast: Presentation of 2014 Deliverables
16 September 2014

OECD: 2014 Deliverables: Guidance on Transfer Pricing Aspects of Intangibles
16 September 2014

OECD: 2014 Deliverables
- Executive Summaries
- Frequently Asked Questions
- Explanatory Statement
16 September 2014

OECD publishes Revised Discussion Draft on the Transfer Pricing Aspects of Intangibles
30 July 2013

 

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