New guidance on hard-to-value intangibles and the transactional profit split method under BEPS Actions 8-10

Jun 26, 2018

The OECD released two reports containing Guidance for Tax Administrations on the Application of the Approach to Hard-to-Value Intangibles, under BEPS Action 8; and Revised Guidance on the Application of the Transactional Profit Split Method, under BEPS Action 10.

The new guidance for tax administration on the application of the approach to hard-to-value intangibles is designed to provide a common understanding and practice among tax administrations on how to apply adjustments resulting from the application of this approach. 

The revised guidance on the profit split method is developed as part of Action 10 of the BEPS Action Plan. This guidance has been formally incorporated into the Transfer Pricing Guidelines, replacing the previous text on the transactional profit split method in Chapter II.