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BEPS Action 9

Assure that transfer pricing outcomes are in line with value creation: risk and capital

Description of this action in OECD's Action Plan (July 2013)

Develop rules to prevent BEPS by transferring risks among, or allocating excessive capital to, group members. This will involve adopting transfer pricing rules or special measures to ensure that inappropriate returns will not accrue to an entity solely because it has contractually assumed risks or has provided capital. The rules to be developed will also require alignment of returns with value creation. This work will be co-ordinated with the work on interest expense deductions and other financial payments.

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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