Martin Zetter provides a roundup of some of the recent changes likely to be of interest to international groups
The transfer pricing world is digesting the latest version of the OECD’s discussion paper on the intangibles chapter of its transfer pricing guidelines.
Elsewhere developments continue at the country level with an eye to preempting much of the BEPS work. Here is a round-up of some of the recent changes likely to be of interest to international groups.
Cost sharing
In the US the IRS has confirmed the adoption of guidance on cost sharing rules. These measures are designed to stop intra-group transfers of intangibles out of the US being under-compensated. The rules concern the valuation of buy-in or platform contribution transactions at an arm’s length price and they adopt ...
