Public comments on the OECD TP documentation and CbC Reporting

Written by Patrick Boone 4 March 2014


On 30 January 2014, the OECD invited comments from interested parties on the Discussion Draft on transfer pricing documentation and country-by-country reporting related to Action point 13 of the BEPS Action PlanOn Monday 03 March 2014, the OECD published the comments received, which will be discussed by Working Party No. 6 of the Committee on Fiscal Affairs at its March and May 2014 meetings, and during the Public Consultation to be held in Paris on 19 May 2014.

Transfer Pricing documentation

As detailed in our Tax Insights from Transfer Pricing of January 2014, the OECD recently released guidance on Transfer Pricing documentation. It is intended to replace Chapter V of the OECD current Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. The discussion draft of 30 January 2014 requires a mandated list of documents to be included in a transfer pricing documentation package. The draft also raises several questions, on which the OECD invited comments.

Public comments to the OECD

In over a thousand pages, stakeholders from academia, industry and consulting firms answered the call of the OECD and submitted comments. PwC appreciates the work of the OECD and welcomes any initiative to lighten the compliance burden of multinationals. We are however concerned by the approach proposed in the Discussion Draft and do not believe it achieves the stated goal of balancing “the usefulness of the data to tax administrators for risk assessment and other purposes with any increased compliance burdens placed on taxpayers”. In this respect, we also shared our view on February 23, 2014 .

We will of course follow up on further developments. Should you have any questions in the meantime, do not hesitate to contact us.

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