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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…

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