Action 8 of the BEPS Action Plan mandated the development of transfer pricing rules or special measures for transfers of hard-to-value intangibles aimed at preventing base erosion and profit shifting by moving intangibles among group members. The outcome of this work is found in Section D.4 of the Revised Chapter VI of the Transfer Pricing Guidelines, contained in the 2015 Final Report for Actions 8-10, "Aligning Transfer Pricing Outcomes with Value Creation" (BEPS TP Report) and now formally adopted as part of the Guidelines. Section D.4 addresses the treatment of hardto-value intangibles (HTVI) for transfer pricing purposes. This document constitutes valuable guidance for tax administrations on the application of the HTVI approach.
