On 4 June 2015, the OECD released a discussion draft for Action 8 (Hard-to-value intangibles) of the Base Erosion and Profiting Shifting (BEPS) Project.

The discussion draft sets out an approach to hard-to-value intangibles and proposes revisions to the guidance in Section D.3 of the 2014 BEPS Report “Guidance on Transfer Pricing Aspects of Intangibles”. The revised guidance explains the diffi…