On March 19 and 20 the OECD will hold its public consultation on action points 8, 9 and 10 of the base erosion and profit splitting (BEPS) project.
Topics on the agenda include:
- recharacterisation of risk allocations for transfer pricing purposes, considering the contractual allocation of risk between group companies and the functions performed to control risk
- several ‘special measures’ proposed by the OECD in relation to the allocation of capital for transfer pricing purposes, transfers of hard to value intangibles, minimal functional entities and CFC rules
- the use of profit split methods
- low value-adding intra –group services
We have a dedicated global BEPS team that tracks the BEPS developments closely and will report on progress against the action plan.