Action on BEPS

These actions address the transfer pricing issues by encouraging companies to consider what value creation by intragroup transactions means for the pricing of those transactions. These transfer pricing-related actions are explained in the report “Aligning Transfer Pricing Outcomes with Value Creation.”

Action 13 of the OECD’s Action Plan on Base Erosion and Profit Shifting (BEPS) is designed to improve transfer pricing documentation. Action 13 recommends that taxpayers should submit extensive documentation about their intercompany transactions and other cross-border transactions and plans to implement mandatory transfer pricing documentation.

The OECD monitors the changing tax and transfer pricing environment and issues new reports as needed. 

Additional Guidance on the Attribution of Profits to Permanent Establishments: A Report Pursuant to Action 7 of the BEPS Action Plan (March 2018) is an update of the report pertaining to BEPS Action 7. Specifically, this report pertains to Action 7's proposed recommendations on assigning profits to permanent establishments resulting from changes in the "Additional Guidance on the Attribution of Profits to Permanent Establishments" in March 2018.

The OECD revised guidance on transactional profit split method (Action 10, June 2018).

Additional guidance addressed an approach to transactions involving hard-to-value intangibles (HTVI) (June 2018).

New transfer pricing guidance on financial transactions addresses Actions 4 and 8-10 (February 2020) and was later incorporated into the OECD’s transfer pricing guidelines.