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June 27, 2018
2018-1310

OECD releases final revised guidance on application of transactional profit split method

The Organisation for Economic Co-operation and Development (OECD) released the final report on June 21, on the revised guidance on the application of the transactional profit split method (the Report). The Report, which has been published as part of Base Erosion and Profit Shifting (BEPS) Action 10, clarifies and expands the guidance on the transactional profit split method (TPSM). It provides the text of the revised guidance on the application of this method, which is to replace section C, part III of Chapter II of the OECD Transfer Pricing Guidelines (OECD TPG). The Report also builds on the work performed and comments received on the discussion drafts that were issued on July 4, 2016 and June 22, 2017 (2017 Discussion Draft).

A Global Tax Alert, attached below, provides additional details.

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