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May 14, 2021

Wednesday, May 26 | BorderCrossings . . . With EY transfer pricing and tax professionals (1 pm ET)

A fresh look at the OECD Transfer Pricing Guidelines

Taxpayers and revenue authorities have been following the revised Organisation for Economic Co-operation and Development (OECD) Transfer Pricing Guidelines for more than five years. This month’s BorderCrossings webcast will provide an in-depth look at and critical analysis of the guidance, its relationship to the Section 482 regulations, and the practical effects of its use in different tax jurisdictions. The revised guidance has been subject to varied interpretations among practitioners and revenue authorities, and the webcast will discuss the impact of the guidelines on transfer pricing today.

Topics will include:

  • The development of the revised guidelines: the Base Erosion and Profit Shifting (BEPS) initiative
  • Revisions to Chapter 1: the treatment of risk and the “accurate delineation of the actual transaction”
  • Revisions to Chapter 6: intangible ownership, hard-to-value intangibles, and development, enhancement, maintenance, protection and exploitation (DEMPE)
  • Revisions to Chapter 8: cost contribution arrangements – similarities and differences from US cost-sharing arrangements
  • Revisions to Chapter 10: financial transactions and the treatment of funding
  • From BEPS 1.0 to BEPS 2.0: the ongoing evolution of the arm’s-length principle

We hope you will be able to join us for this important webcast.

Date: Wednesday, 26 May 2021

Time: 1:00–2:15 p.m. EDT New York/Toronto; 10:00–11:15 a.m. PDT Los Angeles/Vancouver

Registration: View Archive here.


  • Joel Cooper, EY Global Transfer Pricing Controversy Tax Desk Leader
  • Joana Dermendjieva, Senior Manager, Transfer Pricing, International Tax and Transaction Services, Ernst & Young LLP


  • Mike McDonald, Managing Director, Transfer Pricing, International Tax and Transaction Services, Ernst & Young LLP

CPE credit offered: 1.4. Recommended field of study: Taxes. Learning objective: Gain an in-depth understanding of the OECD Transfer Pricing Guidelines and be able to explain their application in different tax jurisdictions, as well as their practical impact on transfer pricing issues. This intermediate level, internet-based group course has no prerequisites or advanced preparation. Final CPE award to be based on content, polling and length of participation. See CPE FAQ for more information.

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