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 guidance on Transfer Pricing Aspects of Intangibles: Revised Chapters I, II and VI of the OECD Transfer Pricing Guidelines
On 16 September 2014, the OECD published its final and interim revisions in relation to Chapters I, II and VI of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. These revisions have been developed in connection with Action 8 of the Action Plan on Base Erosion and Profit Shifting that is focused
As indicated in a newspost earlier this week, the BEPS deliverables for the September 2014 deadline have been published on 16 September 2014 and are available on the OECD website. Please find herewith a link to a summary PwC Bulletin in this respect, highlighting the key take-aways of the reports.
The OECD is keeping its word in preparing and delivering on the objectives as they have been set in the BEPS Action Plan. The deliverables for the September 2014 deadline have just been published and are available on the OECD website (link below). The OECD has published 7 reports (Digital Economy, Hybrid Mismatches, Harmful Tax, Treaty Abuse, Intangibles
Download In July 2013, the OECD released its Revised Discussion Draft on the Transfer Pricing Aspects of Intangibles. PwC immediately informed its network of what had changed compared to the prior Discussion Draft. Now we are also providing you with the more detailed comments we sent the OECD regarding their Revised Discussion Draft. The following
Download 120 business commentators from at least 70 companies (including corporations, consulting firms, law firms and industry organisations) convened in Paris from 12 to 14 November 2012 to discuss three important OECD Discussion Draft topics, including : The Intangibles Draft Safe Harbours Timing Issues PwC was present on this the fourth public consultation on the
Download The highly anticipated Discussion Draft of Chapter VI of the OECD’s Transfer Pricing Guidelines and Related Provisions (the Intangibles chapter), clearly shows that the OECD has made significant progress since they kicked off the project in November 2010. Some of the highlights we discuss are the definitional aspects of intangibles, ownership and entitlement to