The BEPS Action Plan: transfer pricing documentation
By Mark Thomas and Michael Louis
In July 2013, the Organisation for Economic Co-operation and Development (OECD) released its Action Plan on Base Erosion and Profit Shifting (BEPS), spearheading the initiative toward greater co-operation and transparency among revenue agencies globally. BEPS concerns primarily arise when taxpayers utilise a combination of local and international tax rules to achieve situations of double non-taxation or less than single taxation by artificially separating income from the taxpayer’s income-generating activities. The OECD, concerned with potential unilateral actions by member states that could result in double taxation, prepared the action plan and is advocating for collaborative tax reform. The primary goal of the OECD’s BEPS initiative is to better align domestic and international taxation with economic reality. The OECD’s analysis and proposals are being released for public review and comment on a rolling basis, and Dentons commentators will continue to follow these developments.
On 30 January 2014, the OECD issued a discussion draft on Transfer Pricing Documentation and Country-by-Country Reporting, addressing BEPS Action 13, which identified the development of improved transfer pricing documentation standards. The discussion draft focused on the importance of standardised contemporaneous documentation requirements to support the taxpayer’s transfer pricing return positions under the arm’s-length principle…
Click on the link below to read the rest of the Dentons briefing.
Sign in or Register to continue reading this article
It's quick, easy and free!
It takes just 5 minutes to register. Answer a few simple questions and once completed you’ll have instant access.Register now
Why register to The Lawyer
In-depth, expert analysis into the stories behind the headlines from our leading team of journalists.
Identify the major players and business opportunities within a particular region through our series of free, special reports.
Receive your pick of The Lawyer's daily and weekly email newsletters, tailored by practice area, region and job function.
More relevant to you
To continue providing the best analysis, insight and news across the legal market we are collecting some information about who you are, what you do and where you work to improve The Lawyer and make it more relevant to you.
News from The Lawyer
Analysis from The Lawyer
Life in Canada is getting harder for firms as commodities prices fall and work volumes slow
Which firms are cutting it in this era of slimline rosters, and who are the GC new brooms making clean sweeps? The Lawyer can reveal all