The Organisation for Economic Co-operation and Development (“OECD”) presented in a September 16, 2014 webcast its first set of deliverables following its Action Plan to address Base Erosion and Profit Shifting (“BEPS”). BEPS refers to the reduction in governments’ tax revenues resulting from the erosion of their tax base, particularly through the shifting of profits by multinational corporations to low-tax or no-tax jurisdictions. Two of these BEPS deliverables address transfer pricing, namely, the transfer pricing of intangibles, and transfer pricing documentation together with country by country reporting.

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