Action Plan

BEPS – Action 8: Hard-to-Value Intangibles

The OECD published its discussion draft  which deals with work in relation to Action 8 of the Action Plan on Base Erosion and Profit Shifting (BEPS) and focuses on arm’s length pricing of intangibles when valuation is highly uncertain at the...

BEPS: Keep Calm and Get Ready for Action 10

On 16 December, the OECD published two discussion drafts on Action 10 and has invited public comments on the transfer pricing aspects of cross-border commodity transactions and on the use of profit splits in the context of global value chains...