The Organisation for Economic Co-operation and Development (OECD) today released a discussion draft concerning work in relation to Action 8 under the base erosion and profit shifting (BEPS) project with respect to hard-to-value intangibles.
Today’s discussion draft [PDF 62 KB] is being released under Action 8 (Assure that transfer pricing outcomes are in line with value creation: Intangibles) and identifies that work needs to be undertaken to develop “transfer pricing rules or special measures for transfer of hard-to-value intangibles.”
The discussion draft sets out an approach for hard-to-value intangibles and proposes revisions to the guidance in Section D.3 of the BEPS report, Guidance on Transfer Pricing Aspects of Intangibles (2014).
As further explained in today’s related OECD release—
Comments are due by 18 June 2015. A public consultation is scheduled for 6-7 July 2015