On 19 June 2015, the OECD published comments received in response to the 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”. Th…