The Organisation for Economic Co-operation and Development (OECD) has released a discussion draft on work in relation to Action 8 of the Action Plan on Base Erosion and Profit Shifting (BEPS).
Action 8 is entitled “Assure that transfer pricing outcomes are in line with value creation: Intangibles”. It requires the development of “rules to prevent BEPS by moving intangibles among group members” and involves updating the guidance on cost contribution arrangements.
According to the OECD, the discussion draft sets out a proposed revision to Chapter VIII of the Transfer Pricing Guidelines. The draft aims to align the guidance in Chapter VIII with the other elements of Action 8 already addressed in the Guidance on Transfer Pricing Aspects of Intangibles (released in September 2014).
Written comments must be submitted by 29 May 2015. A public consultation meeting is due to be held in Paris at the OECD Conference Centre on 6 or 7 July 2015.
