On 23 May 2016 the OECD Council gave its approval to the amendments to the transfer pricing guidelines recommended in the final report of the project on base erosion and profit shifting (BEPS). The amendments were contained in the final report on BEPS Actions 8 to 10 on aligning transfer pricing outcomes with value creation and Action 13 on transfer pricing documentation and country by country reporting.

Conforming amendments are being made to other parts of the Guidelines such as the chapter on business restructurings. These further amendments are likely to be published for consultation in the near future. Those changes are then likely to be approved later in 2016.