OECD/G20 Base Erosion and Profit Shifting Project
- 2313-2612 (online)
- 2313-2604 (print)
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. A key focus of this work is to eliminate double non-taxation. However in doing so, new rules should not result in double taxation, unwarranted compliance burdens or restrictions to legitimate cross-border activity.
Guidance on Transfer Pricing Aspects of Intangibles
- 16 Sep 2014
- 9789264219212 (PDF) ;9789264219205(print)
This document contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation in the area of intangibles. The changes clarify the definition of intangibles and provide guidance for related parties; including transactions involving intangibles and the transfer pricing treatment of local market features and corporate synergies. Some transfer pricing issues relating to intangibles are closely related to other issues that are to be addressed during 2015, most notably in relation to the allocation of risk among MNE group members and recharacterisation of transactions. Because of those interactions some sections of this document are in intermediate form and will be finalised in 2015.
- Action Plan on Base Erosion and Profit Shifting
- Developing a Multilateral Instrument to Modify Bilateral Tax Treaties
- Preventing the Granting of Treaty Benefits in Inappropriate Circumstances
- Neutralising the Effects of Hybrid Mismatch Arrangements
- Addressing Base Erosion and Profit Shifting
- Countering Harmful Tax Practices More Effectively, Taking into Account Transparency and Substance
- OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2010
- Guidance on Transfer Pricing Documentation and Country-by-Country Reporting