The guidance on HTVIs is likely to have a considerable impact on the development of transfer pricing compliance, write Vladimir Milic and Anton Hume (BDO).
On 20 January 2022 the OECD released the latest edition of its Transfer pricing guidelines for multinational enterprises and tax administrations (‘the OECD TP guidelines’).
This edition primarily consolidates previously published agreed reports stemming from the OECD/G20 BEPS project on:
the transactional profit split method;
the application of the approach to hard to value intangibles (HTVIs); and
financial transactions.
While the stated aims of the new edition is for consolidation and consistency the guidance on HTVIs in particular is likely have a considerable impact on the future development of both the OECD TP guidelines and the broader world of transfer pricing compliance which is why it is the focus of this article.
Background
The OECD guidelines...
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The guidance on HTVIs is likely to have a considerable impact on the development of transfer pricing compliance, write Vladimir Milic and Anton Hume (BDO).
On 20 January 2022 the OECD released the latest edition of its Transfer pricing guidelines for multinational enterprises and tax administrations (‘the OECD TP guidelines’).
This edition primarily consolidates previously published agreed reports stemming from the OECD/G20 BEPS project on:
the transactional profit split method;
the application of the approach to hard to value intangibles (HTVIs); and
financial transactions.
While the stated aims of the new edition is for consolidation and consistency the guidance on HTVIs in particular is likely have a considerable impact on the future development of both the OECD TP guidelines and the broader world of transfer pricing compliance which is why it is the focus of this article.
Background
The OECD guidelines...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
