BEPS Actions 8, 9 and 10: Transfer Pricing Update

Tax Analysis:July 27, 2015/China

On 7 July 2015 the OECD, as part of its work on the Action Plan to address Base Erosion and Profit Shifting (BEPS), provided an update on Actions 8, 9 and 10 in relation to the transfer pricing of intangibles, risk and capital, and other high risk transactions. (Tax Analysis:July 27, 2015/China)

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The update was provided by the OECD Secretariat in a public consultation meeting. It does not reflect a consensus view from the G20/OECD governments involved but is designed to aid businesses' understanding of the process to finalise the work and provide 'direction of travel' indicators in key areas, such as the transfer pricing of risk.

This newsletter explains following topics;

(1) Deloitte Comments and Business Next Steps
(2) Changes to the Transfer Pricing Guidelines
(3) Risk
(4) Cash Boxes
(5) Recognition of the accurately delineated transaction
(6) Intangibles
(7) Profit splits
(8) Dispute resolution
(9) Timetable and Next Steps
(10) Mainland China Practice and Observation

>> Click for Japanese [BEPS行動計画8、9、10: 移転価格アップデート]

(154KB, PDF)

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