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Addressing Difficulties in Accessing Comparables Data for Transfer Pricing Analyses

 

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

Published: 22 June 2017

 

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The Platform for Collaboration on Tax – 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 responds to a request by the Development Working Group of the G20, and addresses an area of tax called "transfer pricing," which refers to the prices corporations use when they transact between members of the same group. How these prices are set has significant relevance for the amount of tax an individual government can collect from a multinational enterprise. The toolkit specifically addresses the ways developing countries can overcome a lack of data needed to implement transfer pricing rules. This data is needed to determine whether the prices the enterprise uses accord with those which would be expected between independent parties. The guidance will also help countries set rules and practices that are more predictable for business. Since the pricing of transactions between related parties in the extractive industries is an issue of particular relevance to many developing countries, the toolkit also addresses the information gaps on prices of minerals sold in an intermediate form (such as concentrates).

The toolkit has been updated following comments on a consultation draft which was made public in January 2017.

 

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