The OECD has incorporated new guidance on hard-to-value intangibles (BEPS action 8) and the transactional profit split method (BEPS action 10) into its main transfer pricing guidelines. The OECD consulted on discussion drafts of the guidance in May/June 2017.
The OECD has incorporated new guidance on hard-to-value intangibles (BEPS action 8) and the transactional profit split method (BEPS action 10) into its main transfer pricing guidelines. The OECD consulted on discussion drafts of the guidance in May/June 2017.
Guidance for tax administrations on the application of the approach to hard-to-value intangibles (BEPS Action 8) includes examples to clarify the application of the hard-to-value intangibles approach in different scenarios; and addresses the interaction between this approach and access to the mutual agreement procedure under the applicable tax treaty.
Revised guidance on the application of the transactional profit split method (BEPS Action 10) retains the basic premise that the profit split method should be applied where it is found to be the most appropriate method in a particular case, but significantly expands the guidance and includes numerous examples.
The OECD has incorporated new guidance on hard-to-value intangibles (BEPS action 8) and the transactional profit split method (BEPS action 10) into its main transfer pricing guidelines. The OECD consulted on discussion drafts of the guidance in May/June 2017.
The OECD has incorporated new guidance on hard-to-value intangibles (BEPS action 8) and the transactional profit split method (BEPS action 10) into its main transfer pricing guidelines. The OECD consulted on discussion drafts of the guidance in May/June 2017.
Guidance for tax administrations on the application of the approach to hard-to-value intangibles (BEPS Action 8) includes examples to clarify the application of the hard-to-value intangibles approach in different scenarios; and addresses the interaction between this approach and access to the mutual agreement procedure under the applicable tax treaty.
Revised guidance on the application of the transactional profit split method (BEPS Action 10) retains the basic premise that the profit split method should be applied where it is found to be the most appropriate method in a particular case, but significantly expands the guidance and includes numerous examples.
.jpg?sfvrsn=335a554c_0 "300 x 250 (MPU)")