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 : Other High Risk Transactions
- 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: other high-risk transactions
Develop rules to prevent BEPS by engaging in transactions which would not, or would only very rarely, occur between third parties. This will involve adopting transfer pricing rules or special measures to:
- clarify the circumstances in which transactions can be recharacterised;
- clarify the application of transfer pricing methods, in particular profit splits, in the context of global value chains; and:
- provide protection against common types of base eroding payments, such as management fees and head office expenses.