OECD/G20 Base Erosion and Profit Shifting Project

English
ISSN: 
2313-2612 (online)
ISSN: 
2313-2604 (print)
http://dx.doi.org/10.1787/23132612
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Addressing base erosion and profit shifting is a key priority of governments around the globe. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. Beyond securing revenues by realigning taxation with economic activities and value creation, the OECD/G20 BEPS Project aims to create a single set of consensus-based international tax rules to address BEPS, and hence to protect tax bases while offering increased certainty and predictability to taxpayers.

Also available in French, German, Spanish
 
Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 - 2015 Final Reports

Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 - 2015 Final Reports You or your institution have access to this content

English
Click to Access: 
    http://oecd.metastore.ingenta.com/content/2315351e.pdf
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Author(s):
OECD
05 Oct 2015
Pages:
192
ISBN:
9789264241244 (PDF) ;9789264241237(print)
http://dx.doi.org/10.1787/9789264241244-en

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The report contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation. The revised guidance focuses on the following key areas: transfer pricing issues relating to transactions involving intangibles; contractual arrangements, including the contractual allocation of risks and corresponding profits, which are not supported by the activities actually carried out; the level of return to funding provided by a capital-rich MNE group member, where that return does not correspond to the level of activity undertaken by the funding company; and other high-risk areas. The report also sets out follow-up work to be carried out on the transactional profit split method which will lead to detailed guidance on the ways in which this method can appropriately be applied to further align transfer pricing outcomes with value creation.

Also available in French, German, Spanish
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Table of Contents

Guidance for Applying the Arm’s Length Principle

Commodity Transactions

Scope of Work for Guidance on the Transactional Profit Split Method

Intangibles

Low Value-adding Intra-group Services

Cost Contribution Arrangements

 
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