RSM Australia

OECD to hold public consultation on several transfer pricing related BEPS action points

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.


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