Transfer pricing: quarterly review of developments

Shiv Mahalingham

Shiv Mahalingham (Duff & Phelps) provides a round-up of news affecting the transfer pricing sphere.

BEPS changes to the OECD Transfer Pricing Guidelines

On 5 October 2015 OECD

Working Party 6 released final reports for BEPS Actions 8 9 and 10 (ensuring that transfer pricing outcomes are in line with value creation). Changes will be adopted to Chapters 1 2 6 7 and 8 of the OECD Transfer Pricing Guidelines.

There is now a helpful framework for the treatment of risk allocation and a six step process has been set out in the OECD guidance looking at:

the nature and sources of risk;
how risks are allocated to contractual...

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