OECD: Discussion draft, hard-to-value intangibles | KPMG Global
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OECD: Discussion draft, guidance on hard-to-value intangibles

OECD: Discussion draft, hard-to-value intangibles

The Organisation for Economic Cooperation and Development (OECD) today released a discussion draft of guidance for implementing rules on “hard-to-value intangibles,” as described in the OECD Transfer Pricing Guidelines.


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Public comments are invited on the discussion draft [PDF 114 KB], and are due by 30 June 2017.


As explained by today’s OECD release, the final report on BEPS Actions 8-10 (Aligning transfer pricing outcomes with value creation) mandates the development of guidance on the implementation of an approach to pricing hard-to-value intangibles, pursuant to the Transfer Pricing Guidelines. The discussion draft released today includes an approach (a set of principles) and examples illustrating application of this approach, and addresses the interaction between the approach to hard-to-value intangibles and the mutual agreement procedure under an applicable treaty.

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