On May 23, 2017 the OECD released a public discussion draft on the implementation guidance on hard-to-value intangibles. The discussion draft provides guidance on the implementation of the approach to pricing transfers of hard-to-value intangibles described in Chapter VI of the Transfer Pricing Guidelines. The OECD invites Interested parties to send comments on this discussion draft by June 30, 2017 by e-mail to This email address is being protected from spambots. You need JavaScript enabled to view it. in Word format.

 

With respect to comments to be submitted the OECD notes that:

·   Please note that comments are not sought on the approach to pricing HTVI agreed under BEPS Action 8 and which was published in the Final Report for Action 8-10 of the BEPS Action Plan. Commentators should concentrate solely on the proposed guidance contained in this discussion draft for the implementation of the approach; and

·   Comments in excess of ten pages should attach an executive summary limited to two pages.

 

The Final Report on Actions 8-10 of the BEPS Action Plan (“Aligning Transfer Pricing Outcomes with Value Creation”) mandated the development of guidance on the implementation of the approach to pricing hard-to-value intangibles contained in Section D.4 of Chapter VI of the Transfer Pricing Guidelines.

 

The OECD expresses that the discussion draft does not yet represent a consensus position of the Committee on Fiscal Affairs or its subsidiary bodies.

 

This discussion draft, presents the principles that should underline the implementation of the approach to hard-to-value intangibles, provides examples illustrating the application of this approach, and addresses the interaction between the approach to hard-to-value intangibles and the mutual agreement procedure under an applicable treaty.

 

Click here to be forwarded to the Public Discussion Draft: “BEPS Action 8 - Implementation Guidance on Hard-to-Value Intangibles” as released by the OECD on may 23, 2017.

 

A link to The Final Report on Actions 8-10 of the BEPS Action Plan (“Aligning Transfer Pricing Outcomes with Value Creation”) can be found in our BEPS LIBRARY.

 


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