BEPS discussion draft on action 10: low value-adding intra-group services

The OECD has published a discussion draft on the transfer pricing of low value-adding intra-group services. This is part of the G20/OECD’s work on BEPS in relation to Action 10 and the transfer pricing of high risk transactions. The draft proposes modifications to Chapter VII of the OECD’s Transfer Pricing Guidelines in relation to intra-group services. The objective is to reduce base erosion through excessive management fees and head office expenses particularly in developing countries.

As with other discussion drafts on BEPS Actions the proposal does not represent a consensus...