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BEPS Action Item 13: The importance of intercompany agreements in a post-BEPS era

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As countries enact legislation in accordance with the OECD’s Base Erosion and Profit-Shifting (BEPS) Action Plan, tax authorities around the world are taking a closer look at intercompany agreements for both content and consistency.

BEPS Action 13 mentions the requirement of presenting a list of important intercompany agreements as part of your Master File documentation. Final guidance on the Local File includes providing copies of all material intercompany agreements concluded by the local entity.

A proactive approach to managing your intercompany agreements is essential for withstanding increased scrutiny.

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