OECD holds public consultation on BEPS-related reporting and transfer pricing issues

 

On 12-13 November 2013, the Organisation for Economic Cooperation and Development (OECD) held a public consultation on several ongoing projects that are related to its Action Plan on Base Erosion and Profit Shifting (BEPS). The two-day meeting was led by OECD Working Party 6, which is the subsidiary group responsible for the OECD’s work on transfer pricing, including the development of the OECD’s Transfer Pricing Guidelines. The meeting focused first on the proposal for a common template for country-by-country reporting of high-level information to tax authorities and the proposal for a common two-tier approach to transfer pricing documentation. The discussion then turned to an in-depth discussion of transfer pricing aspects of intangibles. These are projects that the OECD has targeted in the BEPS Action Plan for completion by September 2014. The meeting concluded with a discussion of other transfer pricing projects that are contemplated under the BEPS Action Plan. These other projects are expected to be the focus of the OECD’s work on transfer pricing through 2015.

The discussion at the OECD consultation underscored the significance of the international tax developments that are under consideration. It also highlighted the aggressive time table that the OECD is planning to meet with respect to these projects. Thus, it is important for companies to be focused now on keeping informed of developments in the OECD and in the relevant countries in which they operate, on assessing the implications of these potential developments for their business models, and on considering getting actively involved in this importance international tax debate.