OECD: BEPS Action 8 (cost contribution arrangements) | KPMG | BE

OECD: Discussion draft, BEPS Action 8 (cost contribution arrangements)

OECD: BEPS Action 8 (cost contribution arrangements)

The Organisation for Economic Co-operation and Development (OECD) today released a discussion draft concerning an action item under the base erosion and profit shifting (BEPS) project—Action 8 (assure that transfer pricing outcomes are in line with value creation: intangibles).


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As noted in today’s OECD release, BEPS Action 8 requires the development of "rules to prevent BEPS by moving intangibles among group members" and involves updating the guidance on cost contribution arrangements.

The Action 8 discussion draft [PDF 276 KB] sets out a proposed revision to Chapter VIII of the Transfer Pricing Guidelines and is intended to align the guidance in that chapter with the other elements of Action 8 already addressed in the Guidance on Transfer Pricing Aspects of Intangibles(September 2014).

Comments concerning the BEPS Action 8 discussion draft are invited, and must be submitted by 29 May 2015.

A public consultation will be held in Paris on 6 or 7 July 2015.

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