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Transfer pricing BEPS deliverables

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Two of the BEPS deliverables that OECD issued on 16 September indicate transfer pricing changes. These relate to intangibles and documentation. The intangibles paper leaves much to be finalised and fundamental concerns remain, such as the wide definition of an intangible for transfer pricing purposes. While the documentation paper gives taxpayers a firmer basis for planning how to respond, the extra reporting involved will mean significant work and compliance costs for many multinational groups.

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