By
TIOL News Service
PARIS,
JUNE 16, 2016: THE OECD
Council has approved the amendments to the Transfer Pricing Guidelines for
Multinational Enterprises and Tax Administrations, as set out in the 2015
BEPS Report on Actions 8-10 "Aligning
Transfer Pricing Outcomes with Value Creation" and the 2015 BEPS Report
on Action 13 "Transfer Pricing Documentation and Country-by-Country Reporting".
These amendments provide further clarity and legal certainty about the status
of the BEPS changes to the Transfer Pricing Guidelines, which were endorsed
by the Council on 1 October 2015, by the G20 Finance Ministers on 8 October
2015, and by the G20 Leaders on 15-16 November 2015.
The amendments approved by the Council translate these BEPS transfer pricing
measures into the Transfer Pricing Guidelines, as well as into the Recommendation
of the Council on the Determination of Transfer Pricing Between Associated
Enterprises [C(95)126/FINAL], which now contains a reference in the Preamble
to these BEPS Reports. Given the way in which the Transfer Pricing Guidelines
are integrated into the domestic law of certain countries, including by direct
reference to the Guidelines themselves, this update process further clarifies
the status of the BEPS changes to the Transfer Pricing Guidelines.
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