OECD releases 14 comments letters on conforming amendments to transfer pricing guidance

The OECD on August 24 released letters from 14 organizations responding to its request for comments on draft conforming amendments to Chapter IX of the OECD Transfer Pricing Guidelines titled “Transfer Pricing Aspects of Business Restructurings.” The draft was released July 4.

The amendments were needed to conform the chapter to the significant changes made to Chapter I of the guidelines in the OECD/G20 base erosion profit shifting (BEPS) project, especially changes concerning the transfer pricing aspects of risk and the accurate delineation of transactions.

The following organizations commented on the guidance: BDI, BEPS Monitoring Group, BIAC, CBI, Deloitte UK, Fidal, International Alliance for Principled Taxation, International Chamber of Commerce, Loyens & Loeff, N.V., NERA Economic Consulting, PwC, Tivalor, USCIB, and WTS.

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