Transfer pricing briefing for January 2015

The OECD released three BEPS transfer pricing papers in December. I will take a brief look at each of them before moving on to country matters.

The OECD invites interested parties to submit comments on all three by 6 February.

The OECD BEPS papers

Discussion draft on revisions to chapter I of the transfer pricing guidelines (including risk recharacterisation and special measures)

It is no surprise that the key point in this report is that a transfer pricing analysis has to be in line with value creation.

Part I of the paper emphasises the importance of delineating the actual transactions accurately. It details guidance...