Action 10 refers to the OECD's guidelines aimed at ensuring that transfer pricing outcomes for intangibles align with value creation. It addresses how multinational enterprises (MNEs) should price their intangible assets, such as patents and trademarks, to prevent base erosion and profit shifting. By emphasizing the need for accurate allocation of profits related to intangible assets, Action 10 seeks to enhance transparency and fairness in international tax systems.
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