Making Sense of the OECD BEPS Project Final Releases.
On October 5, 2015, the OECD released its final BEPS deliverables. This special edition of the Transfer Pricing Times focuses specifically on two final reports:
- Action Item 4 - Limiting Base Erosion Involving Interest Deductions and Other Financial Payments
- Action Items 8-10 – Aligning Transfer Pricing Outcomes with Value Creation which includes guidance on:
- Risk, Recharacterization and Special Measures
- Correlative Adjustments to Chapter VI
- Hard-to-Value Intangibles (HTVI)
- Cost Contributions Arrangements (CCAs)
- Transactional Profit Splits
- Commodity Transactions
- Low Value Services
Given that these final reports totaled nearly 300 pages, this edition cannot provide an exhaustive summary of the content in those reports. This article focuses on the most material changes relative to discussion drafts released largely at the end of 2014. Many of the changes were made in response to the public written commentary received following the issuance of the draft and the public consultations, both of which Duff & Phelps participated in actively.