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Transfer pricing briefing for March 2015

Martin Zetter (Macfarlanes) reviews the latest transfer pricing developments, including this month's OECD's public consultation on transfer pricing papers.

OECD public consultation

The OECD held a public consultation on the four recent transfer pricing papers in Paris on 19 and 20 March in relation to actions 8 9 and 10 of the BEPS action plan. The first day dealt with the paper on revisions to Chapter 1 of the transfer pricing guidelines on risk and recharacterisation; and profit splits low value adding services and commodity transactions were discussed on the second day.

Governments from 43 countries took part along with nearly 100 taxpayers and their representatives. Delegates from the BEPS Monitoring Group a network of individuals sponsored by tax campaigning organisations also took part.

Each session started with presentations by invited speakers on particular topics followed by open discussion. As chair...

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