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OECD Intangibles Project and Related Transfer Pricing Work

OECD Intangibles Project and Related Transfer Pricing Work. Joseph L. Andrus Head of Transfer Pricing Unit OECD. Status of WP6 project on intangibles. Discussion Draft issued on 6 June 2012 Interim draft - Not a consensus document 1000+ pages of public comments submitted in September 2012

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OECD Intangibles Project and Related Transfer Pricing Work

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  1. OECD Intangibles Project and Related Transfer Pricing Work Joseph L. Andrus Head of Transfer Pricing Unit OECD

  2. Status of WP6 project on intangibles • Discussion Draft issued on 6 June 2012 • Interim draft - Not a consensus document • 1000+ pages of public comments submitted in September 2012 • Public consultation November 2012 with well over 200 attendees • Ongoing work on additional intangibles issues • Likely a further (complete) discussion draft in 2013

  3. Key issues on intangibles • Transfer Pricing treatment of local market advantages and corporate synergies • Treatment of assembled workforce and goodwill • Entitlement to intangible related returns • Role of functions, risks, and investment in determining intangible ownership • Valuation techniques and the relevance of accounting valuations including PPAs • Intangibles with highly uncertain value

  4. Base erosion and profit shifting • In part a response to intense political pressures • Mandated by G20 – diagnostic report in mid-February • Focus on six interrelated “pressure areas” • Mismatches in entity and instrument characterization • Delivery of digital goods and services • Related party financing • Transfer pricing / risk shifting and intangibles • Effective anti-avoidance measures – GAAR, CFC and thin capitalization • Preferential regimes

  5. Other OECD Transfer Pricing Work • Safe harbours • Documentation • Low value added services • Risk Assessment Handbook • Tax and development

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