Global Transfer Pricing Conference: Transfer Pricing in a Post-BEPS World

10 February 2016 - 12 February 2016
Hosted By: Institute for Austrian and International Tax Law

On February 11th 2016, NERA Vice President, Sebastien Gonnet gave a presentation at the Global Transfer Pricing Conference organized by WU (Vienna University of Economics and Business). The topic of the conference was “Transfer Pricing in a Post-BEPS World”, and Mr. Gonnet’s presentation, entitled: Transfer Pricing, Allocation of Risk and Recharacterization (BEPS Actions 8, 9 and 10), covered the work of the OECD on “Transfer Pricing, Allocation of Risk and Recharacterization” (Actions 8, 9, and 10 of the BEPS Action Plan), which has developed proposals for a substantial revision of the OECD Transfer Pricing Guidelines with regard to a number of closely related topics, which are “at the heart of the arm’s length principle”. Amongst others, the proposed changes aim at emphasizing the importance of accurately delineating the actual transactions and include guidance on the relevance and allocation of risk.

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