OECD invited interested stakeholders for public comments on a discussion draft which provides guidance on the implementation of the approach to pricing transfers of hard-to-value intangibles described in Chapter VI of the Transfer Pricing Guidelines.
Action 8 of the BEPS Action Plan addresses transfer pricing rules or special measures for transfer of hard-to-value intangibles. The Final Report on Actions 8-10 of the BEPS Action Plan mandated the development of guidance on the implementation of the approach to pricing hard-to-value intangibles ("HTVI") contained in Section D.4 of Chapter VI of the Transfer Pricing Guidelines.
The discussion draft presents the principles that should underline the implementation of the approach to HTVI, provides examples illustrating the application of this approach, and addresses the interaction between the approach to HTVI and the mutual agreement procedure under an applicable treaty.
OECD also clarified that comments are not sought on the approach to pricing HTVI agreed under BEPS Action 8 and which was published in the Final Report for Action 8-10 of the BEPS Action Plan. Interested parties are invited to send comments on this discussion draft by 30 June 2017.
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