BEPS Action Plan 8: Transfer pricing of intangibles

(First of two parts)
IN THIS INSTALLMENT of our series on the Base Erosion and Profit Shifting (BEPS) initiatives of the Organization for Economic Co-operation and Development (OECD), we will tackle Action Plan 8 on the revisions to Chapters I, II and VI of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (2010) (the “2010 OECD TP Guidelines”), which addressed a number of transfer pricing issues on intangibles, namely: