BEPS Plan: new rules of transfer pricing administration

Abstract

The article deals with the basic provisions of Base Erosion and Profit Shift ing Plan (BEPS Plan) and examines what ramifications its implementation will have. The provisions of the Final Report on BEPS Actions 8-10, which deal with transfer pricing issues, are thoroughly analyzed. It is pointed out that the most important revisions of the OECD Transfer Pricing Guidelines (2010) refer to the application of the arm’s length principle, transactions with intangible assets and commodities, transfer pricing rules for intra-group service arrangements and transactional profit split method. The article presents a classification of intra-group services for tax control purposes.