This report contains revised standards for transfer pricing documentation incorporating a master file, local file, and a template for country-by-country reporting of revenues, profits, taxes paid and certain measures of economic activity. The revised standardised approach will require taxpayers to articulate consistent transfer pricing positions and will provide tax administrations with useful information to assess transfer pricing and other BEPS risks, make determinations about where audit resources can most effectively be deployed, and, in the event audits are called for, provide information to commence and target audit enquiries. Country-by-country reports will be disseminated through an automatic government-to-government exchange mechanism. The implementation package included in this report sets out guidance to ensure that the reports are provided in a timely manner, that confidentiality is preserved and that the information is used appropriately, by incorporating model legislation and model Competent Authority Agreements forming the basis for government-to-government exchanges of the reports.
The report contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation. The revised guidance focuses on the following key areas: transfer pricing issues relating to transactions involving intangibles; contractual arrangements, including the contractual allocation of risks and corresponding profits, which are not supported by the activities actually carried out; the level of return to funding provided by a capital-rich MNE group member, where that return does not correspond to the level of activity undertaken by the funding company; and other high-risk areas. The report also sets out follow-up work to be carried out on the transactional profit split method which will lead to detailed guidance on the ways in which this method can appropriately be applied to further align transfer pricing outcomes with value creation.
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Public comments received on discussion draft on BEPS Action 8 (Hard-to-value intangibles)
On 4 June 2015, interested parties were invited to comment on a discussion draft on Action 8 (Hard-to-value intangibles) of the BEPS Action Plan.
Pushing forward efforts to boost transparency in international tax matters, the OECD today released a package of measures for the implementation of a new Country-by-Country Reporting plan developed under the OECD/G20 BEPS Project.
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Release of a discussion draft on BEPS Action 8 (Hard-to-value intangibles)
Public comments are invited on a discussion draft which deals with work in relation to Action 8 of the Action Plan on Base Erosion and Profit Shifting
On 29 April 2015, the OECD invited comments from interested parties on a discussion draft on revisions to Chapter VIII of the Transfer Pricing Guidelines on Cost Contribution Arrangements. This work relates to Action 8 of the BEPS Action Plan.
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Comments received on discussion draft on Action 8 (Cost contribution arrangements) of the BEPS Action Plan
Public comments are invited on this discussion draft which deals with work in relation to Action 8 of the BEPS Action Plan.