BEPS ACTION 10: PROPOSED MODIFICATIONS TO …

BEPS ACTION 10: PROPOSED MODIFICATIONS TO chapter VII OF THE transfer pricing GUIDELINES RELATING TO LOW VALUE-ADDING INTRA-GROUP SERVICES DISCUSSION DRAFT OF THE PROPOSED MODIFICATIONS TO chapter VII OF THE transfer pricing GUIDELINES RELATING TO LOW VALUE-ADDING INTRA-GROUP SERVICES 3 November 2014 Work in relation to ACTION 10 of the BEPS ACTION Plan (other high risk transactions) In the 19 July 2013 BEPS ACTION Plan, the OECD was directed to [d]evelop rules to prevent BEPS by engaging in transactions which would not, or would only very rarely, occur between third parties. This will involve adopting transfer pricing rules or special measures to provide protection against common types of base eroding payments, such as management fees and head office expenses. Under this mandate, Working Party No. 6 on the Taxation of Multinational Enterprises has developed a simplified transfer pricing approach for low value-adding intra-group services which leads to revisions in chapter VII of the OECD transfer pricing Guidelines.

discussion draft of the proposed modifications to chapter vii of the transfer pricing guidelines relating to low value-adding intra-group services

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  Chapter, Transfer, Pricing, Transfer pricing

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