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OECD: Guidance on hard-to-value intangibles, transactional profit split method

OECD: Guidance on BEPS Actions 8 and 10

The Organisation for Economic Cooperation and Development (OECD) today released new guidance on the application of the approach to hard-to-value intangibles and the transactional profit split method under Action 8 and Action 10, respectively, of the base erosion and profit shifting (BEPS) project.


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As noted in today’s OECD release, the follow-up work of the two reports was mandated by the OECD/G20 report Aligning transfer pricing outcomes with value creation (October 2015) as part of the final BEPS package. The report contained revised guidance—such as transfer pricing issues relating to transactions involving intangibles; contractual arrangements including the contractual allocation of risks and corresponding profits that are not supported by the activities actually carried out; the level of return to funding provided by a capital-rich multinational enterprise group member when that return does not correspond to the level of activity undertaken by the funding company; and other high-risk areas. 


Read Guidance for tax administrations on the application of the approach to hard-to-value intangibles (BEPS Action 8)

Read Revised guidance on the application of the transactional profit split method (BEPS Action 10)

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