Transcription of DISCUSSION DRAFT ON TRANSFER PRICING …
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DISCUSSION DRAFT ON TRANSFER PRICING …
Public Consultation DISCUSSION DRAFT ON. TRANSFER PRICING . DOCUMENTATION AND. CbC REPORTING. 30 January 2014. PROPOSED DISCUSSION DRAFT . In the 19 July 2013 BEPS Action Plan, the OECD was directed to [d]evelop rules regarding TRANSFER PRICING documentation to enhance transparency for tax administration, taking into account the compliance costs for business. The rules to be developed will include a requirement that MNE's provide all relevant governments with needed information on their global allocation of the income, economic activity and taxes paid among countries according to a common template . This paper contains an initial DRAFT of revised guidance on TRANSFER PRICING documentation and country-by- country reporting. It is submitted for comment by interested parties. This document does not necessarily reflect consensus views of either the Committee on Fiscal Affairs (CFA) or of Working Party n 6 (WP6).
1 . PROPOSED DISCUSSION DRAFT . In the 19 July 2013 BEPS Action Plan, the OECD was directed to “[d]eveloprules regarding transfer pricing documentation to enhance transparency for tax administration, taking into account the compliance
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