Transfer pricing

Release of a discussion draft on BEPS Action 8 (Cost contribution arrangements)


29/04/2015 – Public comments are invited on a discussion draft which deals with work in relation to Action 8 of the Action Plan on Base Erosion and Profit Shifting (BEPS).


Action 8 ("Assure that transfer pricing outcomes are in line with value creation: Intangibles") requires the development of "rules to prevent BEPS by moving intangibles among group members" and involves updating the guidance on cost contribution arrangements. The discussion draft sets out a proposed revision to Chapter VIII of the Transfer Pricing Guidelines and is intended to align the guidance in that chapter with the other elements of Action 8 already addressed in the Guidance on Transfer Pricing Aspects of Intangibles released in September 2014.


Interested parties are invited to submit written comments by 29 May 2015 (no extension will be granted) and should be sent by email to in both PDF and Word format. They should be addressed to Andrew Hickman, Head of Transfer Pricing Unit, Centre for Tax Policy and Administration.


Please note that all comments received regarding this consultation draft will be made publicly available. Comments submitted in the name of a collective "grouping" or "coalition" or by any person submitting comments on behalf of another person or group of persons, should identify all enterprises or individuals who are members of that collective, or the person(s) on whose behalf the commentator(s) are acting.


Public Consultation

A public consultation on the Discussion Draft and other topics will be held on 6-7 July 2015 at the OECD Conference Centre in Paris. Speakers and other participants at the public consultation will be selected from among those providing timely written comments on the Discussion Draft. Details on how to attend the public consultation are available on line: