{"id":22795,"date":"2013-10-23T07:53:14","date_gmt":"2013-10-23T06:53:14","guid":{"rendered":"http:\/\/www.taxresearch.org.uk\/Blog\/?p=22795"},"modified":"2013-10-23T07:54:22","modified_gmt":"2013-10-23T06:54:22","slug":"my-submission-to-the-oecd-on-transfer-pricing-documentation","status":"publish","type":"post","link":"https:\/\/www.taxresearch.org.uk\/Blog\/2013\/10\/23\/my-submission-to-the-oecd-on-transfer-pricing-documentation\/","title":{"rendered":"My submission to the OECD on transfer pricing documentation"},"content":{"rendered":"

The OECD has now published the submission<\/a> I made to them on transfer pricing documentation on behalf of the BEPS Monitoring Group.<\/p>\n

That informal grouping is, as the submission notes:<\/p>\n

a\u00a0group of experts on various aspects of international tax, set up by a number of civil\u00a0society organizations which research and campaign for tax justice including the\u00a0Global Alliance for Tax Justice, Tax Justice Network, Christian Aid, Action Aid,\u00a0Oxfam, Tax Research UK and others.<\/p><\/blockquote>\n

As the submission says:<\/span><\/p>\n

We welcome the White Paper issued by the OECD on transfer pricing\u00a0<\/span>documentation. In particular we believe that the proposed two-tier structure of master\u00a0and local files that is proposed is very helpful because it will simplify documentation\u00a0requirements for both tax administrations and firms, and is a step towards the\u00a0combined and country-by-country reporting<\/strong> that we believe is vital if base erosion\u00a0and profit shifting by multinational corporations is to be tackled.<\/p><\/blockquote>\n

I've added the emphasis. The goal has to be the creation of a reporting system that ensures all countries have the information they need on a timely and universal basis to ensure they can manage the tax risk that\u00a0multinational corporations create for them.<\/p>\n

As the submission then says:<\/p>\n

Our main concerns relate to what appear to us to be omissions from the planned\u00a0transfer pricing documentation. These relate to:<\/p>\n

a. The lack of a statement of the purpose of transfer pricing documentation in\u00a0this document, which as a result means there is no structure to the proposals\u00a0made;<\/p>\n

b. The lack of a clear systematic approach to the document to be supplied\u00a0which would, in our opinion, make the undertaking of a transfer pricing risk\u00a0assessment harder to achieve, in turn meaning that there may be an\u00a0inappropriate selection of transfer pricing audits undertaken;<\/p>\n

c. No discussion of the issue of country-by-country reporting in the proposed\u00a0documentation; we expect that the request from the G8 will ensure that this\u00a0matter will be considered;<\/p>\n

d. The omission of a requirement to report data on the likely key drivers of\u00a0profit allocation.<\/p><\/blockquote>\n

The OECD is taking tentative steps in the right direction with the BEPS project. It has a long ay to go if it is to provide a coherent approach to tackling international tax abuse through profit shifting.<\/p>\n

NB: My thanks are due to the\u00a0Joseph Rowntree Charitable Trust for making the work on this type of project possible<\/p>\n","protected":false},"excerpt":{"rendered":"

The OECD has now published the submission I made to them on transfer pricing documentation on behalf of the BEPS Monitoring Group. That informal grouping
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