Nov 152015
(First of two parts)
Action 9 of the Base Erosion and Profit Shifting (BEPS) 2015 Final Reports deals with transferring risks among, and allocating excessive capital to, group members, as part of the consolidated Actions 8 -10 on aligning transfer pricing (TP) outcomes with value creation. Action 9, together with Action 10 (Other high-risk transactions), revises Chapter I, Section D (Guidance for applying the arm’s length principle) of the Organization for Economic Cooperation and Development (OECD) TP Guidelines.