Centre for Tax Policy and Administration

Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 - 2015 Final Reports

In series:OECD/G20 Base Erosion and Profit Shifting Projectview more titles

Published on October 05, 2015

Also available in: Spanish, French


The report contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation. The revised guidance focuses on the following key areas: transfer pricing issues relating to transactions involving intangibles; contractual arrangements, including the contractual allocation of risks and corresponding profits, which are not supported by the activities actually carried out; the level of return to funding provided by a capital-rich MNE group member, where that return does not correspond to the level of activity undertaken by the funding company; and other high-risk areas. The report also sets out follow-up work to be carried out on the transactional profit split method which will lead to detailed guidance on the ways in which this method can appropriately be applied to further align transfer pricing outcomes with value creation.





Join the discussions with senior members from the OECD's Centre for Tax Policy and Administration on the final outputs of the OECD/G20 Base Erosion and Project Shifting Project, including the next steps and the involvement of developing countries. 

  • A live press conference for journalists at 2:00-3:00 PM, CEST (Paris, GMT +01:00) with Pascal Saint-Amans, Director, CTPA.
  • A live BEPS webcast for tax experts at 4:00-5:30 PM, CEST (Paris, GMT +01:00) with senior members of CTPA.



Base Erosion and Profit Shifting (BEPS) refers to tax planning strategies that exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations where there is little or no economic activity, resulting in little or no overall corporate tax being paid.