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OECD - Base Erosion & Profit Shifting

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Chapter 10

OECD and G20 BEPS Action Plan: Changes to the International Tax System

• The (BEPS) Project, an ambitious plan undertaken jointly by the OECD and G20 to overhaul the global international tax system, culminated with a huge report of recommendations that, if adopted, could have a significant impact on cross-border trade.

Assure Transfer Pricing Outcomes are in line with Value Creation : Intangibles

Develop rules to prevent BEPS by moving intangibles among group members. This will involve:

1. adopting a broad and clearly delineated definition of intangibles;
2. ensuring that profits associated with the transfer and use of intangibles are appropriately allocated in accordance with (rather than divorced from) value creation;
3. developing transfer pricing rules or special measures for transfers of hard-to-value intangibles; and
4. updating the guidance on cost contribution arrangements.

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