Latest Documents

Transfer Pricing Guidance on Financial Transactions: Inclusive Framework on BEPS: Actions 4, 8-10

This report contains transfer pricing guidance on financial transactions, developed as part of Actions 4 and 8-10 of the OECD/G20 Inclusive Framework on BEPS Action Plan.

Singapore - Transfer Pricing Country Profile

Singapore - Transfer Pricing Country Profile

Guidance for Tax Administrations on the Application of the Approach to Hard-to-Value Intangibles - BEPS Action 8

The new guidance is aimed at reaching a common understanding and practice among tax administrations on how to apply adjustments resulting from the application of the approach to hard-to-value intangibles (HTVI). This guidance should improve consistency and reduce the risk of economic double taxation by providing the principles that should underlie the application of the HTVI approach.

Revised Guidance on the Application of the Transactional Profit Split Method - BEPS Action 10

This report contains revised guidance on the profit split method, developed as part of Action 10 of the BEPS Action Plan. This guidance will be incorporated into the OECD Transfer Pricing Guidelines, replacing the previous text on the transactional profit split method in Chapter II.

Additional Guidance on the Attribution of Profits to a Permanent Establishment under BEPS Action 7

This report contains additional guidance on the attribution of profits to permanent establishments resulting from the changes in the Report on BEPS Action 7 to Article 5 of the OECD Model Tax Convention.

Addressing Difficulties in Accessing Comparables Data for Transfer Pricing Analyses

This Toolkit responds to a request by the Development Working Group of the G20, and addresses an area of tax called "transfer pricing," which refers to the prices corporations use when they transact between members of the same group. How these prices are set has significant relevance for the amount of tax an individual government can collect from a multinational enterprise.

OECD releases a discussion draft on the implementation guidance on hard-to-value intangibles

Public comments are invited on a discussion draft which provides guidance on the implementation of the approach to pricing transfers of hard-to-value intangibles described in Chapter VI of the Transfer Pricing Guidelines.

OECD releases further BEPS guidance on Country-by-Country reporting and country-specific information on implementation

The Inclusive Framework on BEPS has released two new documents to support the global implementation of Country-by-Country (CbC) reporting (BEPS Action 13).

Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 - 2015 Final Reports

Transfer Pricing Documentation and Country-by-Country Reporting, Action 13 - 2015 Final Report