OECD proposes conforming amendments to transfer pricing guidelines on business restructuring

The OECD on July 4 published proposed amendments to Chapter IX of the transfer pricing guidelines dealing with business restructuring to conform the guidance to recent changes made to other chapters on account of the final OECD/G20 base erosion profit shifting (BEPS) reports. Significant changes were made to Chapter 1 of the guidelines concerning delineating transaction and allocating risk.

The OECD is not open to any discussions about the concepts in the draft; it just seeks feedback on whether the conforming changes address all inconsistencies between Chapter IX and the revised transfer pricing guidelines and whether the proposed changes remove all duplication in the chapters.

Comments on the draft are due August 16.

The OECD said it intends to publish a revised version of the transfer pricing guidelines in 2016.

See:

• Conforming Amendments to Chapter IX of the Transfer Pricing Guidelines