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<h1>BEPS Actions 8-10: Aligning Transfer Pricing with Value Creation, Focusing on Intangibles, Risk, and Profit Allocation</h1> Actions 8-10 of the BEPS initiative focus on aligning transfer pricing with value creation, addressing issues like the valuation of intangibles and risk allocation in multinational enterprises (MNEs). Action 8 targets transfer pricing for intangibles, Action 9 emphasizes risk control and returns allocation, and Action 10 addresses profit allocation and transfer pricing methods. The OECD's revised guidance on the transactional profit split method and hard-to-value intangibles aims to improve consistency and reduce double taxation risks. Additionally, new guidance on financial transactions clarifies the application of the arm's length principle, addressing capital structure and pricing of financial transactions.
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