On 29 April 2015, the OECD released a discussion draft for Action 8 (Cost contribution arrangements) of the Base Erosion and Profiting Shifting (BEPS) Project.
Action 8 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 o…