OECD: Draft guidance on transfer pricing under consideration

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OECD: Draft guidance on transfer pricing under considerationThe OECD has recently published an initial draft of revised guidance on transfer pricing documentation and country-by-country reporting. This draft is the integral part of the 19 July 2013 Base Erosion Profit Shifting (BEPS) Action Plan by OECD. Public comments are encouraged to review BEPS Action Plan 13. Issues on which comments have been invited include whether work on the Action Plan should include development of additional standard forms and questionnaires beyond the country-by-country reporting template. The OECD has also asked for comments on the circumstances in which it might be appropriate for tax authorities to share their risk assessment with taxpayers, as well as the appropriate scope and nature of possible rules relating to the production of information and documents in the possession of associated enterprises outside the jurisdiction requesting the information. Finally, it has requested suggestions as to the measures that could be taken to simplify the documentation process, and the measures that can be taken to safeguard the confidentiality of sensitive information without limiting tax administration access to relevant information.