OECD publishes comments on TP Comparability Data and Developing Countries paper
On 11 March 2014, the OECD invited comments from interested parties on the paper on Transfer Pricing Comparability Data and Developing Countries. This paper discusses four possible approaches to addressing the concerns expressed by developing countries over the lack of data on comparables (expanding access to data sources for comparables, more effective use of data sources
OECD guidance on Transfer Pricing Aspects of Intangibles: Revised Chapters I, II and VI of the OECD Transfer Pricing Guidelines
On 16 September 2014, the OECD published its final and interim revisions in relation to Chapters I, II and VI of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. These revisions have been developed in connection with Action 8 of the Action Plan on Base Erosion and Profit Shifting that is focused
BEPS: OECD is gearing up towards the September deadlines
The OECD’s Action Plan on Base Erosion and Profit Shifting (BEPS) was published in July 2013 with a view to addressing perceived flaws in international tax rules. The 40-page Action Plan, which was negotiated and drafted with the active participation of the OECD member states, contains 15 separate action points or work streams, some of which are
The EU Joint Transfer Pricing Forum published the transfer pricing profiles of EU Member States.
The EU Joint Transfer Pricing Forum has published various transfer pricing profiles of EU Member States on its website. These profiles contain information for the EU Member States on the domestic transfer pricing framework and regulations, transfer pricing documentation requirements, information on dispute resolution, competent authorities’ contact details and other transfer pricing related topics. The
PwC comments on the Discussion Draft on Transfer Pricing Comparability Data and Developing Countries
PwC has provided the OECD with its comments on the ‘discussion draft on transfer pricing comparability data and developing countries’ on 11 April 2014. PwC agrees with the OECD in that comparability is at the heart of transfer pricing, and that the application of the arm’s length principle often relies on a comparison of the prices charged
PwC’s comments on OECD TP documentation draft and CbC reporting
PwC has released its response to the OECD’s Discussion Draft launched in the context of BEPS Action point 13. Click here to read PwC’s Comments The Discussion Draft was issued on January 30 and comments were due yesterday. A public OECD consultation meeting will follow on May 19. Needless to say that we are monitoring
EU JTPF agrees on common criteria for acceptance of compensating adjustments
Download In January 2014, the EU Joint Transfer Pricing Forum (‘JTPF’) finalised its Report on Compensating Adjustments (‘the Report’). The document offers practical solutions to both EU tax administrations and taxpayers on how to deal with the issue of compensating adjustments. 1. Background The Report is the response of the JTPF on the level of
OECD draft on transfer pricing documentation and country-by-country reporting
Download Webcast Multinational enterprises (MNEs) will face materially increased compliance burdens as a result of the hotly debated proposals to report to tax administrations, on a country-by-country basis, extensive details of their income, taxes, and business activities. Further, extensive changes to the current requirements for transfer pricing documentation reporting will also add to this burden.
