The OECD released the 2017 Edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. Based on the 2010 Transfer Pricing Guideline, the updated edition provides guidance on how to apply the Arm’s length principle under BEPS context.
In 2015, OECD published 15 final reports on the BEPS project which have been welcomed globally. This 2017 TP Guideline integrates propositions of the report regarding several aspects and covers both substantial rules and procedural rules such as documentation and filing. All the revisions have been approved during 2013 to 2017. The main outcome of the amendments includes:
This latest edition contains the revised Recommendation of the OECD Council on the Determination of Transfer Pricing between Associated Enterprises [C(95)126/FINAL] as well. The revised recommendation relates to tackling BEPS and establishing the Inclusive Framework on BEPS. By involving non-OECD members into the revision, the Guideline managed to expand its impact. In addition, the OECD Council allows the Committee on Fiscal Affairs to approve by consensus future amendments to the Guidelines which are essentially of a technical nature.
Transfer Pricing Associates introduces TPA BEPS Desk. If you have any questions, or need more detailed advice on any aspects of BEPS related issues, please get in touch with us. The TPA Global network has alliance partners throughout the world, and the network can provide multi-disciplinary approach on today's critical transfer pricing challenges faced by multinational enterprises.
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