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By Philippe Neefs Habiba Kobci, KPMG Luxembourg
On 19 December 2014, the Organization for economic co-operation and development (OECD) released a discussion draft on revision to Chapter 1 of the OECD Transfer pricing guidelines. This draft covers actions 8, 9 and 10. The purpose of this article is to underline the new guidance and statement regarding allocation of risks and capital structure (BEPS Action 9).
Action 9 of the BEPS action plan aims at preventing multinational enterprises (MNEs) from base erosion and profit shifting from high tax jurisdiction to low tax jurisdiction trough either the excessive allocation of capital to group companies or transfer of risks to group companies solely for tax minimization purposes. Action 9...
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