OECD/G20 Base Erosion and Profit Shifting Project

English
ISSN: 
2313-2612 (online)
ISSN: 
2313-2604 (print)
DOI: 
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. 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.

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Guidance on Transfer Pricing Aspects of Intangibles

Guidance on Transfer Pricing Aspects of Intangibles You or your institution have access to this content

English
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    http://oecd.metastore.ingenta.com/content/2314291e.pdf
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Author(s):
OECD
16 Sep 2014
Pages:
132
ISBN:
9789264219212 (PDF) ;9789264219205(print)
DOI: 
10.1787/9789264219212-en

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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.

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Table of Contents

Executive summary
Amendments to Chapters I – II of the Transfer Pricing Guidelines
Amendments to Chapter VI of the Transfer Pricing Guidelines
Chapter VI. Special considerations for intangibles
Annex to Chapter VI. Examples to illustrate the guidance on special considerations for intangibles

 
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