ARTICLE · 08 OCTOBER 2014

OECD Issues Work On BEPS Actions

MNP LLP

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The deliverable in respect of action 8 sees revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation in the area of intangibles.

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The Organization for Economic Cooperation and Development (OECD) has released the first components of its comprehensive plan for creating an agreed set of international rules for fighting base erosion and profit shifting (BEPS) and ending opportunities for double non-taxation. The four model legal instruments and three reports are the first seven deliverables of the OECD's 15-action plan for fighting BEPS. In particular, two deliverables relate specifically to transfer pricing as follows:

Action 8 — guidance on transfer pricing aspects of intangibles; and
Action 13 — guidance on transfer pricing documentation, including a country-by-country reporting template.

Action 8: Intangibles

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