OECD Working Party No. 6 releases a discussion draft on the Transfer Pricing Aspects of Intangibles

The OECD's Committee on Fiscal Affairs (CFA) invites public comments on the draft Commentary on the International VAT Neutrality Guidelines. This draft Commentary provides guidance on the practical implementation of the six International VAT Neutrality Guidelines approved by the CFA in July 2011. Public comments should be sent before 26 September 2012 to vat@oecd.org.

The OECD Committee on Fiscal Affairs invites public comments on a revised discussion draft on the meaning of “beneficial owner”, a term that is used in Articles 10, 11 and 12 of the OECD Model Tax Convention.

The OECD Committee on Fiscal Affairs invites public comments on a revised discussion draft on the definition of “permanent establishment” that is included in Article 5 of the OECD Model Tax Convention.

The OECD Committee on Fiscal Affairs invites public comments on a revised discussion draft on tax treaty issues related to emissions permits/credits, which addresses the application of the provisions of the OECD Model Tax Convention to the cross-border granting and trading of emissions permits and credits.

On 6 June 2012, the OECD released an invitation to comment on a discussion draft on the Transfer Pricing Aspects of Intangibles. The comments received in response to this invitation have been published. This edition replaces the previous edition released on 28 September 2012.

On 6 June 2012, the OECD released an invitation to comment on a discussion draft on the revision of the Safe Harbours Section in Chapter IV of the Transfer Pricing Guidelines. The comments received in response to this invitation have been published. This edition replaces the previous edition released on 28 September 2012.

On 6 June 2012, the OECD released an invitation to comment on a discussion draft on timing issues relating to transfer pricing. The comments received in response to this invitation have been published. This edition replaces the previous edition released on 28 September 2012.

On 12-14 November 2012, transfer pricing experts from governments met with private sector representatives to discuss the transfer pricing discussion drafts released on 6 June 2012. The agenda for the meeting, presentation material submitted by private sector participants, and a list of participants have now been published.

On 19 October 2012, the OECD Committee on Fiscal Affairs released for public comment a revised discussion draft on tax treaty issues related to emissions permits and credits. The OECD has now published the comments received on this revised discussion draft.

On 19 October 2012, the OECD Committee on Fiscal Affairs released for public comment a revised discussion draft on the definition of “permanent establishment” (Article 5) of the OECD Model Tax Convention. The OECD has now published the comments received on this revised discussion draft.

The Steering Committee of the OECD Global Forum on Transfer Pricing publishes a Draft Handbook on Transfer Pricing Risk Assessment. This Handbook is intended to provide practical guidance to tax administrations in both OECD and non-OECD economies regarding the process of conducting transfer pricing risk assessments. Interested parties are invited to provide comments by 13 September 2013.

The OECD Committee on Fiscal Affairs invites public comments on a discussion draft on the tax treaty treatment of various payments, such as non-competition payments, that may be made following the termination of an employment.

The OECD released for public comment a Revised Discussion Draft on Transfer Pricing Aspects of Intangibles. The Revised Discussion Draft updates and expands an earlier discussion draft released in June 2012 to reflect comments received and further discussions of country delegates to Working Party No. 6 of the Committee on Fiscal Affairs. Comments of interested persons are requested by 1 October 2013.

Following the recent invitations for public comment on four new draft elements of the OECD International VAT/GST Guidelines, the OECD has now published the comments received which will be used to inform the OECD’s work in this area.

On 30 April 2013, the OECD invited comments from interested parties on the new Draft Handbook on Transfer Pricing Risk Assessment, produced by the Steering Committee of the OECD Global Forum on Transfer Pricing. The OECD now publishes the comments received.

A public consultation will be held at the OECD Conference Centre on 12-13 November 2013. The public consultation is open to all interested persons and will be attended by country delegates to Working Party No. 6 of the OECD Committee on Fiscal Affairs. Persons interested in attending must register in advance through the OECD website.

On 30 July 2013, the OECD invited comments from interested parties on the Revised Discussion Draft on Transfer Pricing Aspects of Intangibles. The comments received in response to this invitation have been published.

The OECD invites public comments on a discussion draft that includes proposed changes to the OECD Model Tax Convention dealing with the operation of ships and aircraft in international traffic.

The OECD Committee on Fiscal Affairs invites public comments on a discussion draft that includes various technical changes to be included in the next update to the OECD Model Tax Convention.

Interested parties are invited to comment on this paper prepared by the OECD in the context of revision to Chapter V of the Transfer Pricing Guidelines.

On 15 November 2013, the OECD Committee on Fiscal Affairs (CFA) invited public comments on a discussion draft on technical changes to be included in the next update to the OECD Model Tax Convention. The OECD has now published the comments received on that discussion draft.

On 15 November 2013, the OECD Committee on Fiscal Affairs (CFA) invited public comments on a discussion draft on changes to the provisions of the OECD Model Tax Convention dealing with the operation of ships and aircraft in international traffic. The OECD has now published the comments received on that discussion draft.

A revision of the timetable for planned stakeholders’ input is now available online with the dates when discussion drafts will be published and public consultations held in relation to the September 2014 BEPS outputs.

On 30 January 2014, the OECD invited comments from interested parties on the Discussion Draft on transfer pricing documentation and country-by-country reporting. The OECD now publishes the comments received.

Public comments are invited on a discussion draft that includes the proposals produced with respect to Action 6 (Prevent Treaty Abuse) of the BEPS Action Plan.

Public comments are invited on discussion drafts that include the proposals produced with respect to Action 2 (Hybrid Mismatch Arrangements) of the BEPS Action Plan.

Public comments are invited on a discussion draft that includes the proposals produced with respect to Action 1 (Tax Challenges of the Digital Economy) of the BEPS Action Plan.

The OECD publishes comments received from interested parties on the discussion draft on Action 6 (Prevent Treaty Abuse) of the BEPS Action Plan.

On 24 March 2014, the OECD invited comments from interested parties on the Discussion Draft on Tax Challenges of the Digital Economy related to Action 1 of the BEPS Action Plan. The OECD now publishes the comments received.

OECD publishes comments received on Action 2 discussions drafts (Neutralise the Effects of Hybrid Mismatch Arrangements)

The Committee on Fiscal Affairs (CFA) invites interested parties to send comments on this discussion draft, which includes the preliminary results of the work carried on with respect to issues related to the artificial avoidance of PE status and includes proposals for changes to the definition of permanent establishment found in the OECD Model Tax Convention.

Action 10 of the Action Plan on Base Erosion and Profit Shifting directs the OECD to develop transfer pricing rules to provide protection against common types of base eroding payments. A discussion draft of proposed modifications to Chapter VII of the Transfer Pricing Guidelines relating to low value-adding intra-group services was released for comment by interested parties today

Public comments are invited on a discussion draft which deals with follow-up work mandated by the Report on Action 6 (“Prevent the granting of treaty benefits in inappropriate circumstances”) of the BEPS Action Plan.

Public comments are invited on the discussion draft on the use of profit splits in the context of global value chains, released as part of the work in relation to Action 10 of the BEPS Action Plan.

Public comments are invited on the discussion draft on the Transfer Pricing aspects of cross-border Commodity transactions released as part of the OECD Centre for Tax Policy's work on Action 10 of the Action Plan on Base Erosion and Profit Shifting.

The OECD’s Committee on Fiscal Affairs invites public comments on two new draft elements of the OECD International VAT/GST Guidelines (the Guidelines). These discussion drafts relate to (i) the place of taxation of business-to-consumer supplies of services and intangibles (B2C Guidelines) and (ii) provisions to support the application of the Guidelines in practice (Supporting provisions).

Public comments are invited on a discussion draft which deals with action 4 (Interest deductions and other financial payments) of the BEPS Action Plan

Public comments are invited on a discussion draft which deals with the work on Action 14 (“Make dispute resolution mechanisms more effective”) of the BEPS Action Plan.

Public comments are invited on this discussion draft which deals with work in relation to Actions 8,9, and 10 of the Action Plan on Base Erosion and Profit Shifting (BEPS).

On 31 October 2014, the OECD invited comments from interested parties on the discussion draft on Action 7 (Prevent the Artificial Avoidance of PE Status) of the BEPS Action Plan. The OECD now publishes the comments received.

On 18 December 2014, the OECD invited comments from interested parties on the discussion draft on Action 14 (Make dispute resolution mechanisms more effective) of the BEPS Action Plan. The OECD now publishes the comments received.

On 3 November 2014, the OECD invited comments from interested parties on the discussion draft of proposed modifications to Chapter VII of the Transfer Pricing Guidelines covering low value-adding intra-group services relating to Action 10 of the BEPS Action plan.

On 19 December 2014, interested parties were invited to comment on the discussion draft on Actions 8, 9 and 10: revisions to Chapter I of the Transfer Pricing Guidelines (Including risk, recharacterisation and special measures) of the BEPS Action Plan. The OECD is grateful to the commentators for their input and now publishes the comments received.

On 16 December 2014, the OECD invited comments from interested parties on a discussion draft on the use of profit splits in the context of global value chains. This work relates to Action 10 of the BEPS Action Plan. The OECD is grateful to the commentators for their input, and now publishes the comments received.

On 16 December 2014, the OECD invited comments from interested parties on a discussion draft on the transfer pricing aspects of cross-border commodity transactions. This work relates to Action 10 of the BEPS Action Plan. The OECD is grateful to the commentators for their input, and now publishes the comments received.

On 18 December 2014, interested parties were invited to comment on the discussion draft on Action 4 (Interest Deductions and other Financial Payments) of the BEPS Action Plan. The OECD is grateful to the commentators for their input and now publishes the comments received.

On 18 December 2014, the OECD invited comments from interested parties on discussion drafts of two new elements of the OECD International VAT/GST Guidelines. These discussion drafts related to (i) the place of taxation of business-to-consumer supplies of services and intangibles (B2C Guidelines) and (ii) provisions to support the application of the Guidelines in practice (Supporting provisions)

Public comments are invited on a discussion draft which deals with action 12 (Mandatory Disclosure Rules) of the BEPS Action Plan.

Public Comments are invited on a discussion draft which deals with Action 11 (Improving the analysis of BEPS) of the BEPS Action Plan.