The OECD’s Revised Discussion Draft contains several important changes. These were based on the comments received on the prior Discussion Draft. The majority of the document provides additional guidance on how to correctly allocate ‘return related to an intangible’ (also described as: ‘intangible related return’). The Revised Discussion Draft states that although contractual relationships between related parties will continue to serve as a starting point for any transfer pricing analysis, the location where material functions related to intangible assets are performed is also considered to be key. This focus on functional value creation is being formalised by the OECD through the concept of ‘important functions’, which consists of the crucial activities and decisions identified under the prior Discussion Draft. Download the full report for more detailed information and the observations PwC made.
-
- Share
-
- Media centre News
- OECD project on intangibles: Revised Discussion Draft released
OECD project on intangibles: Revised Discussion Draft released
Published on 2 July 2013

Newsletter
Value means different things to different people
That’s why you can decide to receive updates only for the issues that matter most to you.
Subscribe today
Belgian Tax Reform
Related news
- The Carbon Border Adjustment Mechanism – It’s official!
- Filed your transfer pricing documentation in due time?
- PwC’s Pillar Two Country Tracker
- European Commission temporarily relaxes State Aid measures in support of the Green Deal Industrial Plan
- EU Green Deal Industrial Plan – Latest developments from the European Commission
© 2016 - PwC. All rights reserved. PwC refers to the PwC network and/or one or more of its member firms, each of which is a separate legal entity.
Please see www.pwc.com/structure for further details.