Global Transfer Pricing Conference: Transfer Pricing Developments around the World

Vienna
22 February 2017 - 24 February 2017
Hosted By: Institute for Austrian and International Tax Law

On 24 February 2017, NERA Director Sébastien 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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