BEPS discussion draft: revised guidance on profit splits

In 2015, the Organization for Economic Co-operation and Development (OECD) released its final reports on base erosion and profit shifting (BEPS). The reports addressed 15 focus areas, including “Aligning Transfer Pricing Outcome with Value Creation, Actions 8-10 — 2015 Final Reports,” issued on Oct. 5, 2015. BEPS Action Plans 8-10 provided discussions regarding, among others, the “Guidance on Applying Arm’s Length Principle” and “Scope of Work for Guidance on the Transactional Profit Split Method.” The discussions mentioned additional work to be conducted by the OECD to produce new guidance on the application of the transactional profit split method.