Latest Documents


  • 24-August-2016

    English

    Public comments received on the conforming amendments to Chapter IX of the OECD Transfer Pricing Guidelines

    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.

  • 4-July-2016

    English

    Release of BEPS discussion drafts on attribution of profits to permanent establishments and revised guidance on profit splits

    Public comments are invited on discussion drafts on "Attribution of Profits to Permanent Establishments" which deals with work in relation to BEPS Action 7 and on the "Revised Guidance on Profit Splits" which deals with work in related to BEPS Actions 8-10 of the OECD/G20 BEPS Action Plan.

  • 4-July-2016

    English

    BEPS Actions

    Developed in the context of the OECD/G20 BEPS Project, the 15 BEPS actions equip governments with domestic and international instruments to address tax avoidance, ensuring that profits are taxed where economic activities generating the profits are performed and where value is created. Under the inclusive framework, over 100 countries and jurisdictions are now collaborating to implement the BEPS measures and tackle BEPS.

  • 4-July-2016

    English

    Public review sought of BEPS Conforming Changes to Chapter IX of the OECD Transfer Pricing Guidelines

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

  • 29-June-2016

    English

    New steps to strengthen transparency in international tax matters: OECD releases guidance on the implementation of country-by-country reporting

    Today the OECD has taken a new step in its continuing efforts to boost transparency in international tax matters with the release of guidance on the implementation of country-by-country (CbC) reporting.

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  • 15-June-2016

    English

    OECD Council approves incorporation of BEPS amendments into the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations

    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".

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  • 2-June-2016

    English

    OECD appoints new Head of the Tax Treaty, Transfer Pricing & Financial Transactions Division in the Centre for Tax Policy and Administration

    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.

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  • 4-March-2016

    English

    Developed and developing countries gather at OECD to deepen their engagement to implement BEPS package

    On 1-3 March 2016, the OECD hosted two important events for the international tax community. The Task Force on Tax and Development and the Global Forum on Transfer Pricing gathered over 230 participants representing 84 jurisdictions and 11 international and regional organisations.

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  • 5-October-2015

    English

    Transfer Pricing Documentation and Country-by-Country Reporting, Action 13 - 2015 Final Report

    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.

  • 5-October-2015

    English

    Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 - 2015 Final 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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