ICC Document & publication

ICC comments on the OECD Discussion Draft on Transfer Pricing Documentation and CbC Reporting (2014)

In the context of the OECD Base Erosion and Profit Shifting (BEPS) Project mandated by the G20, ICC submitted high level and fundamental comments on the OECD’s Discussion Draft on Transfer Pricing Documentation and Country by Country Reporting.

ICC submitted high level and fundamental comments to OECD’s Discussion Draft on Action 13 of the OECD Base Erosion and Profit Shifting (BEPS) Action Plan.

BEPS refers to tax planning strategies that exploit gaps and mismatches in tax rules to make profits ‘disappear’ for tax purposes and/or to shift profits to locations where there is little or no real activity but the taxes are low resulting in little or no overall corporate tax being paid.

OECD’s BEPS Action 13 calls for a review of the existing transfer pricing documentation rules and the development of a template for country-by-country (CbC) reporting of income, taxes and economic activity for tax administrations.

The discussion draft on Transfer Pricing Documentation and CbC Reporting contains a draft of revised guidance to develop rules to enhance transparency for tax administration, taking into account the compliance costs for business.