OECD Discussion Draft on transfer pricing aspects of hard-to-value intangibles published
The OECD has published a discussion draft on the arm’s length pricing of intangibles when valuation is highly uncertain at the time of the transaction or the intangibles are hard to value. The discussion draft, released on 4 June 2015, is part of Action Item 8 of the OECD’s Base Erosion and Profit Shifting (BEPS)
OECD publishes Discussion Draft on cost contribution arrangements
On 29 April 2015, the OECD issued a Discussion Draft on the transfer pricing aspects of cost contribution arrangements (‘CCAs’) under Action 8 of the BEPS action plan. The Draft proposes fundamental modifications to Chapter VIII of the OECD Transfer Pricing Guidelines: With respect to measuring the value of contributions to CCAs and the tax
