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Transfer pricing briefing for March 2015

Speed read

The OECD held a public consultation on the BEPS transfer pricing papers. Concerns remain on recharacterisation, the importance of labour over capital and the trend towards profit splits. However, these are early drafts and it is reasonable to hope that these points will be reflected in the subsequent proposals. Separately, Canada issued guidance on intra-group services, giving some interesting context to the OECD position. Morocco progresses with its APA programme.

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