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OECD: Comments invited on revised transfer pricing guidelines

OECD transfer pricing guidelines

The Organisation for Economic Cooperation and Development (OECD) on 4 July 2016 issued a release inviting comments concerning changes to the OECD transfer pricing guidelines—specifically with respect to Chapter IX, "Transfer Pricing Aspects of Business Restructurings”—as prompted by changes to the guidelines set out in the base erosion and profit shifting (BEPS) recommendations.


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As noted in an OECD release, extensive changes to the transfer pricing guidelines were made by recommendations concerning BEPS Actions 8-10, Aligning transfer pricing outcomes with value creation, and recommendations concerning BEPS Action 13, Transfer pricing documentation and country-by-country reporting, and were approved in May 2016. The OECD Committee on Fiscal Affairs conducted further work to make conforming changes to other parts of the OECD transfer pricing guidelines that have not been modified by the BEPS recommendations, in order to develop a consolidated version of the guidelines.

The most significant conforming changes are contained in Chapter IX, “Transfer Pricing Aspects of Business Restructurings.” These changes aim to:

  • Conform existing general guidance in Chapter IX on risk and recognition of controlled transactions to the guidance contained in the revised Chapter I resulting from the BEPS recommendations
  • Refine existing in guidance in Chapter IX with the updates to the rest of the guidelines resulting from the BEPS project

Stakeholders are invited to review the revised parts of the guidelines. Comments are due by 16 August 2016.

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