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

Tom Goldstein, who was represented by US law firm Munger, Tolles & Olson, denied wilfully cheating on his taxes and blamed errors on his staff
Multinationals face rising TP scrutiny as global rules diverge. As Daniel Moalusi argues, strong, consistent documentation is now essential to minimise audit risk and protect tax positions
The profession is fundamentally restructuring itself around what tax and accounting work should be, a Thomson Reuters leader told ITR
The big four firm is consolidating 16 entities across the region to create a single 6,000-partner behemoth
Brazil’s tax reform unifies consumption taxes to simplify rules, centralise administration and reduce legal uncertainty
The ever-expansive firm has once again attracted a former ‘big four’ talent to lead the new offering
The amended double taxation avoidance agreement removes France’s most favoured nation status for tax treaty benefits
The levies extended beyond the president’s ‘legitimate reach’, the Supreme Court ruled
While Brazil’s consumption tax overhaul led to a short-term spike in tax advisory demand, we are now in a period of ‘normalisation’ marked by decreased recruitment
The expanded firm will comprise roughly 8,500 employees, including 550 partners; in other news, Paul Hastings and Macfarlanes made senior tax hires
Gift this article