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 2026

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

An OECD report on taxation of the digital economy is expected by the end of 2026, according to the group of nations
Trophy assets are evolving from personal indulgences to structured investments, prompting family offices to prioritise tax efficiency, governance discipline, and cross-border compliance
As demand for complex, cross-border private client counsel spikes, Patrick McCormick sees opportunity in starting from scratch
As part of an exclusive global alliance, KPMG will become one of Anthropic’s ‘preferred consultants’ for private equity
In the second part of this series, the focus shifts to how taxpayers can manage ongoing risks across the lifecycle of cross-border structures
Jurisdictions have moved to ensure that multinationals are not punished for late GIR filings due to a lack of available filing portals or exchange relationships
HMRC’s push for unified tax adviser registration won’t prevent every instance of improper conduct, but it is good for taxpayers and the UK’s reputation
Elsewhere, the UAE’s tax office has issued an update on registration penalties and two firms have been busy making lateral hires
The case sits within a context of Brazil signalling that it is replacing informal discretion and ambiguity with structures that reward analytical rigour, one expert tells ITR
Jeff Soar lifts the lid on WTS UK’s ambitious recruitment plans, the firm's positioning against the big four, and why tax is the perfect profession for AI
Gift this article