On 4 June 2015, the OECD released a discussion draft for Action 8 (Hard-to-value intangibles) of the Base Erosion and Profiting Shifting (BEPS) Project.
The discussion draft sets out an approach to hard-to-value intangibles and proposes revisions to the guidance in Section D.3 of the 2014 BEPS Report “Guidance on Transfer Pricing Aspects of Intangibles”. The revised guidance explains the difficulties faced by tax administrations in verifying the arm’s length basis on which pricing was determ…