International - The OECD Intangibles Project and the Concept of “Intangible Related Return”
- C. Garbarino; M. D’Avossa
- European Taxation, 2015 (Volume 55), No 1
- 8 December 2014
This article examines the OECD’s recent work regarding certain transfer pricing aspects of intangibles as reflected in BEPS Action Plan No. 8. In particular, the authors provide a description of the project, as well as the activities undertaken by Working Party No. 6 up to March 2014, describe the interim work performed by Working Party No. 6 in connection with the attribution of the “Intangible Related Return” to members of a multinational group and address comments on the “Intangible Related Return” concept received by Working Party No. 6 from business commentators.