The public consultation on 7 July 2015 confirmed some of the key changes agreed to the existing OECD Transfer Pricing Guidelines:
Chapter I: additional language to address the delineation of the actual intra-group transaction (including the distinction between ‘conduct’ and ‘contractual arrangements’) risk and recognition of the accurately delineated transaction locational advantages workforce in place and synergistic benefits;
Chapter II: additional language to address commodity transactions;
Chapter V: additional language to include the finalised guidance on transfer pricing documentation;
Chapter VI: additional language to address intangibles (including hard to value intangibles). A separate...
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The public consultation on 7 July 2015 confirmed some of the key changes agreed to the existing OECD Transfer Pricing Guidelines:
Chapter I: additional language to address the delineation of the actual intra-group transaction (including the distinction between ‘conduct’ and ‘contractual arrangements’) risk and recognition of the accurately delineated transaction locational advantages workforce in place and synergistic benefits;
Chapter II: additional language to address commodity transactions;
Chapter V: additional language to include the finalised guidance on transfer pricing documentation;
Chapter VI: additional language to address intangibles (including hard to value intangibles). A separate...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
2015 confirmed some of the key changes agreed to the existing OECD Transfer Pricing Guidelines:
