ICC Document & publication

ICC comments on Discussion Draft on Conforming Changes to Chapter IX of the OECD Transfer Pricing Guidelines

In the context of the OECD Base Erosion and Profit Shifting (BEPS) Project mandated by the G20, ICC submitted high level and fundamental comments on the OECD’s Discussion Draft on Conforming Changes to Chapter IX of the OECD Transfer Pricing Guidelines, Transfer Pricing Aspects of Business Restructurings.

ICC submitted high level and fundamental comments to OECD’s Discussion Draft on Conforming Changes to Chapter IX of the OECD Transfer Pricing Guidelines, Transfer Pricing Aspects of Business Restructurings.

The conforming amendments to Chapter IX of the Transfer Pricing Guidelines are prompted by the changes to the Guidelines set out in the 2015 Base Erosion and Profit Shifting reports, specifically 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. The extensive changes to the Guidelines made by these Reports were approved by Council on 23 May 2016.

The purpose of the review was to establish that real or perceived inconsistencies with the revised parts of the Guidelines have been appropriately addressed, and duplication appropriately removed.