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 : Risk & Capital
- 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: risks and capital
Develop rules to prevent BEPS by transferring risks among, or allocating
excessive capital to, group members.
This will involve adopting transfer
pricing rules or special measures to ensure that inappropriate returns
will not accrue to an entity solely because it has contractually assumed
risks or has provided capital.
The rules to be developed will also require alignment of returns with
value creation. This work will be co-ordinated with the work on interest
expense deductions and other financial payments..