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OECD Updates Transfer Pricing Guidelines

by Ulrika Lomas, Tax-News.com, Brussels Friday, July 14, 2017

On July 10, 2017, the OECD released the 2017 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.

The guidance consolidates changes resulting from the base erosion and profit shifting (BEPS) project. It incorporates the following revisions of the 2010 edition into a single publication:

  • The substantial revisions introduced by the 2015 BEPS Reports on Actions 8-10 (aligning transfer pricing outcomes with value creation) and Action 13 (transfer pricing documentation and country-by-country reporting);
  • The revisions to Chapter IX of the TP Guidelines to conform the guidance on business restructurings to the revisions introduced by the 2015 BEPS Reports on Actions 8-10 and 13; and
  • The revised guidance on safe harbors in Chapter IV of the TP Guidelines.

The latest edition also includes the revised Recommendation of the Council on the Determination of Transfer Pricing Between Associated Enterprises (C(95)126/FINAL).

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