The Taxation of Offshore Indirect Transfers – A Toolkit


Cover page of Toolkit For Addressing Difficulties in Accessing Comparables Data for Transfer Pricing Analyses - Discussion Draft

Published 4 June 2020


Download the toolkit


The Platform for Collaboration on Tax (PCT) – 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 "Toolkits" to help guide developing countries in the implementation of policy options for issues in international taxation of greatest relevance to these countries.

This toolkit addresses a concern of particular significance to developing countries, mostly but not exclusively natural resource rich countries—primarily from the perspective of the country where the underlying assets are located. Taxation of the indirect transfer of assets such as mineral rights, and other assets generating location specific such as licensing rights for telecommunications, has been the subject of protracted public interest. This topic is a concern in many developing countries, magnified by the revenue challenges that governments around the world face as a consequence of the COVID-19 crisis.

The PCT toolkit gives practical and coherent guidance for developing countries on considerations that might arise when deciding to tax offshore indirect transfers (OIT), types of assets to tax in such cases and how to design and implement OIT taxation in domestic law. It also suggests two models for domestic legislation which countries may adopt to bring to tax such transfers.

The toolkit has been finalised taking into account comments received during two rounds of public consultation in 2017 and 2018, producing significant interest and a number of detailed responses from a range of groups representing country authorities, civil society organization and the private sector.

The launch of this toolkit will be complemented with a launch webinar in the coming weeks. French and Spanish versions of the toolkit will follow, as well as virtual learning opportunities based on the toolkit.




Further information



Documents connexes


Also AvailableEgalement disponible(s)