Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 - 2015 Final
Reports
The report contains revisions to the OECD Transfer Pricing Guidelines to align transfer
pricing outcomes with value creation. The revised guidance focuses on the following
key areas: transfer pricing issues relating to transactions involving intangibles;
contractual arrangements, including the contractual allocation of risks and corresponding
profits, which are not supported by the activities actually carried out; the level
of return to funding provided by a capital-rich MNE group member, where that return
does not correspond to the level of activity undertaken by the funding company; and
other high-risk areas. The report also sets out follow-up work to be carried out on
the transactional profit split method which will lead to detailed guidance on the
ways in which this method can appropriately be applied to further align transfer pricing
outcomes with value creation.
Published on October 05, 2015Also available in: German, Spanish, French, Polish
In series:OECD/G20 Base Erosion and Profit Shifting Projectview more titles