New Changes To The Oecd Transfer Pricing Guidelines
Knowledge • New Changes To The Oecd Transfer Pricing Guidelines
Knowledge • New Changes To The Oecd Transfer Pricing Guidelines
On 15 June 2016, the OECD Council approved the amendments to the ‘Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations’ (Also as the OECD Transfer Pricing Guidelines). The changes are the most significant amendments introduced into the OECD Transfer Pricing Guidelines since 2010.
The amendments involved replacing some of the Chapters with the BEPS final reports of the following actions:
Key changes
|
Chapter Number |
Amendment |
|
One: The arm’s length principle Section D: Guidance for applying the arm’s length principle |
Section D has been deleted and replaced entirely with new guidance |
|
Two: Transfer Pricing Methods Section B Comparable Uncontrolled Price Method |
New paragraph after paragraph 2.16 with additional guidance on commodity transactions |
|
Two: Transfer Pricing Methods Section A: Selection of most appropriate transfer pricing method |
New paragraph after paragraph 2.9 with additional guidance on the application of profit split method |
|
Five: Documentation |
This Chapter has been deleted and replaced entirely with new guidance from Action 13 Transfer Pricing Documentation and Country by Country Reporting |
|
Six: Special consideration for intangible property |
This Chapter has been deleted and replaced entirely with new guidance |
|
Seven: Special consideration for intra-group services |
This Chapter has been deleted and replaced entirely with new guidance |
|
Eight: Cost Contribution Arrangements |
This Chapter has been deleted and replaced entirely with new guidance |
For more information on how these changes can affect you contact Transfer Pricing Solutions
Australia
+61 (3) 59117001
reception@transferpricingsolutions.com.au
Singapore
+65 31585806
services@transferpricingsolutions.asia