OECD - Base Erosion & Profit Shifting
OECD and G20 BEPS Action Plan: Changes to the International Tax System
Assure Transfer Pricing Outcomes are in line with Value Creation : Intangibles
- 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.
Aligning transfer pricing
outcomes with value creation: intangibles
Develop rules to prevent BEPS by moving intangibles among group members. This will involve:
- adopting a broad and clearly delineated definition of intangibles;
- ensuring that profits associated with the transfer and use of intangibles are appropriately allocated in accordance with (rather than divorced from) value creation;
- developing transfer pricing rules or special measures for transfers of hard-to-value intangibles; and
- updating the guidance on cost contribution arrangements.