OECD debated necessity of cost contribution chapter in BEPS

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

OECD debated necessity of cost contribution chapter in BEPS

In an interview with TPWeek, Andrew Hickman, head of the OECD’s transfer pricing unit, said the OECD debated whether a chapter on cost contribution arrangements was necessary in the final BEPS guidance released last month.



Hickman also explained why publishing a company’s country-by-country report would be unhelpful and discussed why the OECD cannot make specific recommendations against patent boxes, despite not agreeing with the principle.

He expanded on Pascal Saint-Amans’ comments about the OECD’s attitude to patent boxes and discussed the nexus approach to these kinds of IP regimes.

The interview covers the further guidance on transfer pricing to be expected in 2016, where Hickman said the OECD has updated 60% to 70% of the transfer pricing guidelines so far. He said the next major addition to these guidelines will be financial transactions.

The full interview can be accessed with a trial or subscription to TPWeek.



more across site & shared bottom lb ros

More from across our site

Recent news of job cuts at EY is symptomatic of how the PwC controversy has tarnished the reputation of the entire ‘big four’
Experts reportedly discussed extending the safe harbour to 2027 to give countries more time to legislate; in other news, Baker McKenzie and Greenberg Traurig made senior tax hires
Awards
Submit your nominations to this year's WIBL Americas Awards by January 23
Recent changes in UK tax rules and cross-border requirements are generating high demand for specialist advice, according to MHA
Hany Elnaggar examines how Gulf Cooperation Council countries are internalising transfer pricing norms within evolving fiscal systems shaped by both Islamic and international influences
Where a TP study of comparables produces an arm’s-length range, and the taxpayer’s filed position is outside that range, HMRC will adjust to the median by default
EY, KPMG, Deloitte, and PwC have all seen a decrease in public sector contracts since the scandal – it is understood
Consoli, a tax partner at Brazilian law firm Martinelli Advogados, tells ITR about the importance of staying at the coalface and constantly learning
Despite legislative gridlock, international investors should be wary of legal precedents set by recent court rulings, which could substantially alter the Spanish tax environment
The new outfit, Ashurst Perkins Coie, will bring together around 3,000 lawyers across 23 countries
Gift this article