February 2019

TRANSFER PRICING: WHAT HAS CHANGED IN OECD’S 2017 GUIDELINES? [PART 2]

Vandana Shah | Gaurav Shah
Chartered Accountants

This article summarises the key additions/ modifications made in the 2017 Guidelines as compared to the earlier Guidelines. The first part of the article, published in the December issue of the Journal, discussed about the general guidance contained in Chapters I to V of the new Transfer Pricing Guidelines issued in 2017 (2017 Guidelines). This part of the article deals with guidance relating to specific transactions:

 

?    Chapter VI – Special Consideration for Intangibles

?    Chapter VII – Special Considerations for Intra-Group     Services,

?    Chapter VIII – Cost Contribution Agreements, and

?    Chapter IX – Business Restructurings

 

1.      Chapter VI - Special Considerations for Intangibles


The 2017 Guidelines have broadened the concept of ‘intangibles’ for transfer pricing purposes, and also provide detailed guidance on intangibles including several aspects of intangibles not addressed in the earlier guidelines. The key differences are discussed in this section. 

 

1.1. 

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