02 May 2016 Intangible BEPS Risks (BNA) James Tobin, a partner with Ernst & Young's International Tax Services group, recently authored an article published in BNA's Tax Management International Journal discussing the OECD BEPS report on Actions 8-10, specifically on the aspects of that report dealing with risk and intangible property (IP). According to the article, OECD BEPS Actions 8-10 basically attribute IP and risk returns to the related parties responsible for development, enhancement, maintenance, protection, and exploitation (DEMPE) and control of risk functions. Further, the report presents intended changes to the OECD Transfer Pricing Guidelines (OECD Guidelines). The author notes, however, that since many countries subscribe to the OECD Guidelines, it has been said that the conclusions in this report immediately take effect in those countries and thus these changes have a much more accelerated effect (at least in those countries) than the other BEPS Actions. The article, published in the April 8, 2016, edition of Tax Management International Journal, is attached below. Document ID: 2016-0789 |
