OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017
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OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017

This 2017 edition of the OECD Transfer Pricing Guidelines incorporates the substantial revisions made in 2016 to reflect the clarifications and revisions agreed in the 2015 BEPS Reports on Actions 8-10 Aligning Transfer pricing Outcomes with Value Creation and on Action 13 Transfer Pricing Documentation and Country-by-Country Reporting. It also includes the revised guidance on safe harbours approved in 2013 which recognises that properly designed safe harbours can help to relieve some compliance burdens and provide taxpayers with greater certainty. Finally, this edition also contains consistency changes that were made to the rest of the OECD Transfer Pricing Guidelines.  The OECD Transfer Pricing Guidelines were approved by the OECD Council in their original version in 1995.

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Chapter
 

Special Considerations for Intra-Group Services You do not have access to this content

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This chapter discusses issues that arise in determining for transfer pricing purposes whether services have been provided by one member of an MNE group to other members of that group and, if so, in establishing arm’s length pricing for those intra-group services. The chapter does not address except incidentally whether services have been provided in a cost contribution arrangement, nor, in such a case, the appropriate arm’s length pricing. Cost contribution arrangements are the subject of Chapter VIII.

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