Prix de transfert

Public comments received on BEPS discussion drafts on attribution of profits to permanent establishments and transactional profit splits


06/10/2017 - On 22 June 2017, interested parties were invited to provide comments on two discussion drafts. The first discussion draft on Attribution of Profits to Permanent Establishments, which deals with work in relation to Action 7 ("Preventing the Artificial Avoidance of Permanent Establishment Status") of the BEPS Action Plan; and  a second one on Revised Guidance on Profit Splits, which deals with work in relation to Actions 8-10 ("Assure that transfer pricing outcomes are in line with value creation") of the BEPS Action Plan. The OECD is grateful to the commentators for their input and now publishes the public comments received.


Public Consultation 

A public consultation on these two discussion drafts will be held on 6-7 November 2017 at the OECD Conference Centre in Paris. Speakers and other participants at the public consultation will be selected from among those providing timely written comments on the discussion drafts.