OECD releases new discussion draft on transfer pricing documentation

By Paul Flignor, Michael F Patton and Ágata Uceda

The Committee of Fiscal Affairs of the Organization of Economic Cooperation and Development (OECD) has released its proposed updated guidelines on transfer pricing documentation, including country-by-country reporting (CbC), Discussion Draft on Transfer Pricing Documentation and CbC Reporting. This discussion draft contains a proposed template for the multinational reporting of global business information and taxes paid to each country in which the multinational operates.

The discussion draft, released on 30 January 2014, is still a work in progress, with the OECD seeking input from the public on several key issues. The OECD is working to a tight deadline to finalise these guidelines by May and will accept written comments through 23 February 2014. A public consultation is likely to be held in March.

The discussion draft is part of the larger OECD initiative on the Base Erosion and Profit Shifting Action Plan announced in February 2013 to reduce perceived taxpayer double non-taxation or the presence of corporate income that is untaxed by any country. Concerns over double non-taxation have led to political and public outcry in Europe, the US and emerging markets…

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