In recent years, without substantially changing the overall function of intangible assets, multinational enterprises have transferred profits generated by the group to countries with low tax burdens through the transfer or centralized management of intangible assets, resulting in serious tax base erosion and profit transfer. It has attracted extensive attention from tax agencies, media, the public and international organizations in various countries. The BEPS Action Plan No. 8-10 proposed by the OECD in 2015 is a response plan to the aggressive tax planning of multinational enterprise groups’ abuse of the intangible asset transfer pricing system by establishing a new analytical framework. This paper makes an in-depth analysis of the new OECD transfer pricing rules for intangible assets, and believes that the introduction of risk control identification standards and the weakening of the legal owner’s status will help solve the problem of inconsistency between value creation and actual economic activities, but there is still room for improvement. In the process of improving domestic rules by referring to and learning from the new OECD rules on transfer pricing of intangible assets, my country needs to better safeguard my country’s interests by combining its comparative advantages and the position of enterprises in the global value chain.