Chapter 1 of the OECD 2017 Guidelines, substantially re-written as a consequence of BEPS Action 8 (¶775-000), provides guidance on how to apply the arm's length principle. The 2017 guidelines apply for accounting periods beginning on or after 1 April 2018. See ¶773-670 for the applicable version of the guidelines for earlier accounting periods. Comparing the 2017 guidelines with the 2010 guidelines, the main changes relate to the following areas:

(1)transfer pricing issues relating to intangibles;

(2)contractual arrangements, including the contractual allocation of risks and corresponding profits, which are not supported by the activities actually carried out;

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