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The OECD proposals on transfer pricing

The OECD has recently published a white paper on transfer pricing documentation and its latest proposals to amend its transfer pricing guidelines on intangibles (see www.lexisurl.com/0oFPB). Comments are invited by 1 October 2013.

Intangibles

The OECD has published the latest proposals to amend its transfer pricing guidelines on intangibles.

This is central to the transfer pricing work in the BEPS project. It aims to make fundamental changes to the way multinationals treat intangible property to prevent perceived abuses of the arm’s length principle. ‘Action 8’ of the BEPS plan specifically addresses intangibles and this discussion document also considers some of the other transfer pricing issues such as the allocation of risks capital and the digital economy.

The OECD guidelines form the UK transfer pricing rules so British companies operating internationally will need to consider these proposals carefully. Even though it is billed as a ‘work in...

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