Latest Documents

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.

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".

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.

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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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.

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16-March-2015

English

Global Forum on Transfer Pricing

On 16 and 17 March 2015, the OECD hosts the Fourth Annual Meeting of the Global Forum on Transfer Pricing in Paris. This meeting is part of a series of Global Forum Meetings dedicated to the Action Plan on Base Erosion and Profit Shifting (BEPS). The 4th Annual Meeting of the Global Forum on Transfer Pricing will focus on the BEPS work already undertaken and the deliverables to be finalised in 2015 relating to transfer pricing.

6-February-2015

English, PDF, 533kb

Action 13: Guidance on the Implementation of Transfer Pricing Documentation and Country-by-Country Reporting

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.

16-September-2014

English

Guidance on Transfer Pricing Documentation and Country-by-Country Reporting

This document contains revised standards for transfer pricing documentation and a template for country-by-country reporting of revenues, profits, taxes paid and certain measures of economic activity. These new reporting provisions, and the transparency they will encourage, will contribute to the objective of understanding, controlling, and tackling BEPS behaviours. Countries participating in the BEPS project will carefully review the implementation of these new standards and will reassess no later than the end of 2020 whether modifications should be made to require reporting of additional or different data. Effective implementation of the new reporting standards and reporting rules will be essential. Additional work will be undertaken to identify the most appropriate means of filing the required information with and disseminating it to tax administrations.

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16-September-2014

English

Guidance on Transfer Pricing Aspects of Intangibles

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.

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