On 4 July 2016, the OECD published a discussion draft setting out proposed revisions to the guidance on the transactional profit split method, as set out in the Base Erosion and Profit Shifting (BEPS) Actions 8-10 (“Aligning Transfer Pricing Outcomes with Value Creation”), 2015 Final Report, together with a number of questions. The questions are intended to elicit responses to be taken into account by Working Party No. 6 in considering revisions to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. The OECD has asked for comments by 5 September 2016 and intends to hold a public consultation on the proposed guidance 11 and 12 October 2016.
Source & more info: PwC