English, PDF, 533kb
Another key objective of the BEPS project is to increase transparency through improved transfer pricing documentation standards. The new guidance presented to the G20 requires country-by-country reporting by multinationals with a turnover above EUR 750 million in their countries of residence starting in 2016.
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.
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).
Spanish, PDF, 203kb
Borrador de Proyecto Sobre Los Aspectos de Precios de Transferencia en Operaciones Transfronterizas de Commodities
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 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.
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
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.
The OECD Committee on Fiscal Affairs (CFA), bringing together 44 countries on an equal footing (all OECD members, OECD accession countries, and G20 countries), has adopted a final set of deliverables described in the Action Plan.
This document contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation in the area of intangibles. The changes clarify the definition of intangibles and provide guidance for related parties; including transactions involving intangibles and the transfer pricing treatment of local market features and corporate synergies. Some transfer pricing issues relating to intangibles are closely related to other issues that are to be addressed during 2015, most notably in relation to the allocation of risk among MNE group members and recharacterisation of transactions. Because of those interactions some sections of this document are in intermediate form and will be finalised in 2015.