OECD updates Multi-Country Analysis of Existing Transfer Pricing Simplification Measures

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

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 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.

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 Council has approved the revision of Section E on safe harbours in Chapter IV of the Transfer Pricing Guidelines. New guidance provides opportunities for countries to relieve some compliance burdens and to provide greater certainty for cases involving smaller taxpayers or less complex transactions. It encourages the use of bilateral or multilateral safe harbours and provides sample MOUs to establish bilateral safe harbours.

As part of its project on transfer pricing simplification, the OECD has released a White Paper on Transfer Pricing Documentation. Comments of interested persons are requested by 1 October 2013.

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.

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.

The OECD will hold a public consultation on the Revised Discussion Draft on Transfer Pricing Aspects of Intangibles and the White Paper on Transfer Pricing Documentation on 12-13 November 2013 at the OECD Conference Centre in Paris, France. The public consultation will also consider other transfer pricing elements of the 19 July 2013 Action Plan on Base Erosion and Profit Shifting.

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 White paper on Transfer Pricing Documentation, released as part of its project on transfer pricing simplification. The OECD now publishes the comments received.

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.

Today, the OECD held a public consultation on transfer pricing topics at the OECD headquarters in Paris. The meeting was attended by delegates from more than 35 countries and by more than 150 representatives of business, academia, civil society and the press.

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 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.

This paper sets out four possible approaches to addressing the concerns over the lack of data on transfer pricing comparables expressed by developing countries.

The OECD will hold a public consultation on the discussion draft on transfer pricing documentation and country-by-country reporting on 19 May 2014 at the OECD in Paris, France.

As the Millennium Development Goals (MDGs) approach their expiry date, we must focus our efforts on ensuring a brighter, more inclusive and sustainable future for all. We face a plethora of common issues: growing inequalities; changing consumption patterns and population dynamics; increasing natural resource scarcity; and ongoing illicit financial flows.

This page shows a full table of comments received from the public on the Interim Draft Paper on Transfer Pricing Comparability Data and Developing Countries.

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 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.

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 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 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.

The OECD will hold a public consultation event on transfer pricing matters on 19-20 March 2015 at the OECD Conference Centre in Paris, France.

Mr Jefferson VanderWolk has been appointed Head of the Tax Treaty, Transfer Pricing & Financial Transactions Division in the Centre for Tax Policy and Administration. He will take up his duties in early July 2016.

On 23 May 2016, the OECD Council approved the amendments to the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations ("Transfer Pricing Guidelines"), as set out in the 2015 BEPS Report on Actions 8-10 "Aligning Transfer Pricing Outcomes with Value Creation" and the 2015 BEPS Report on Action 13 "Transfer Pricing Documentation and Country-by-Country Reporting".

Interested parties are invited to review the conforming changes to Chapter IX of the Transfer Pricing Guidelines, "Transfer Pricing Aspects of Business Restructurings."

On 4 July 2016, interested parties were invited to review the conforming amendments to Chapter IX of the OECD Transfer Pricing Guidelines, "Transfer Pricing Aspects of Business Restructurings". The OECD is grateful to the commentators for their input and now publishes the comments received.

Responding to a request by the Development Working Group of the G20, the Platform for Collaboration on Tax – a joint initiative of the IMF, OECD, UN and World Bank Group – has developed a draft toolkit designed to assist developing countries in an important area of international tax policy: transfer pricing.

The Platform for Collaboration on Tax (PCT) – a joint initiative of the International Monetary Fund (IMF), Organisation for Economic Co-operation and Development (OECD), United Nations (UN) and World Bank Group – has published a toolkit to provide practical guidance to developing countries to better protect their tax bases.

Mr. Tomas Balco has been appointed Head of the Transfer Pricing Unit in the Centre for Tax Policy and Administration. He will take up his duties on 4 September 2017.

The OECD Transfer Pricing Guidelines provide guidance on the application of the “arm’s length principle”, which represents the international consensus on the valuation, for income tax purposes, of cross-border transactions between associated enterprises.

The Platform for Collaboration on Tax – a joint initiative of the IMF, OECD, UN and World Bank Group – is seeking public feedback on a draft toolkit designed to help developing countries tackle the complexities of taxing offshore indirect transfers of assets, a practice by which multinational corporations try to minimise their tax liability.

The OECD will hold a public consultation event on transfer pricing matters on 6-7 November at the OECD Conference Centre in Paris, France.

The OECD has published updated versions of transfer pricing country profiles (TPCP), reflecting the current transfer pricing legislation and practices of a large number of participating countries.

On August 1st 2017, interested parties were invited to provide comments on the discussion draft of a toolkit on the Taxation of Offshore Indirect Transfers. The Platform for Collaboration on Tax is grateful to the commentators for their input and now publishes the public comments received during the consultation period.

The OECD has published 14 new and 2 updated transfer pricing country profiles, reflecting the current transfer pricing legislation and practices of participating countries. The country profiles, which are now available for 44 countries, contain up-to-date and harmonised information on key aspects of transfer pricing legislation, provided by countries themselves.

Public comments are invited on the future revision of Chapter IV, “Administrative Approaches to Avoiding and Resolving Transfer Pricing Disputes” of the Transfer Pricing Guidelines, and the future revision of Chapter VII, “Special Considerations for Intra-Group Services”, of the Transfer Pricing Guidelines.

Public comments received on the scope of the future revisions of Chapter IV (Administrative Approaches) and Chapter VII (Intra-group services) of the Transfer Pricing Guidelines

Public comments are invited on a discussion draft on financial transactions, which deals with follow-up work in relation to Actions 8-10 ("Assure that transfer pricing outcomes are in line with value creation") of the BEPS Action Plan.

The Platform for Collaboration on Tax – a joint initiative of the IMF, OECD, UN and World Bank Group – has undertaken, at the request of the G20, the development of a series of “toolkit” reports to help guide developing countries in the implementation of policy options for issues in international taxation of greatest relevance to these countries.

The OECD has published new transfer pricing country profiles for Costa Rica, Greece, Republic of Korea, Panama, Seychelles, South Africa and Turkey. In addition, it has also updated the information contained in Singapore’s profile. The country profiles are now available for 52 countries.

On 3 July 2018, interested parties were invited to provide comments on a discussion draft on financial transactions, which deals with follow-up work in relation to Actions 8-10 (“Assure that transfer pricing outcomes are in line with value creation”) of the BEPS Action Plan. The OECD is grateful to the commentators for their input and now publishes the public comments received.

The Forum on Tax Administration (FTA), the 53 leading global tax administrations, met in Chile on 26-28 March and agreed an ambitious agenda focused on tax certainty, enhanced tax co-operation and the collective challenges of digital transformation.

The OECD has just released new transfer pricing country profiles for Chile, Finland and Italy, bringing the total number of countries covered to 55. In addition, the OECD has updated the information contained in the country profiles for Colombia and Israel.

The OECD and Brazil’s Receita Federal (RFB) issued a joint statement at the high-level event held on 11 July 2019 in Brasília, Brazil, to present the outcomes of the 15-month work programme carried out by OECD jointly with RFB.

The Platform for Collaboration on Tax – a joint initiative of the IMF, OECD, UN and World Bank Group – is seeking feedback from the public on a draft toolkit designed to help developing countries in the implementation of effective transfer pricing documentation requirements.