OECD Tax Evasion Rules Could Spur IP Operations Shifts

Law360, New York (October 7, 2015, 6:33 PM EDT) -- The Organization for Economic Cooperation and Development’s new transfer pricing guidelines released Monday contain stricter rules for attributing profits from intellectual property, which may require multinational companies to shift employees and operations to satisfy the requirements.

The changes to the guidelines were put forth as part of the OECD’s project to tamp down tax base erosion and profit shifting. In a report on transfer pricing, the organization laid out the expectation that profits attributed to intangibles must be associated with risk and development of the intangible and mere ownership of IP is not enough to assign returns to an entity....

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