The OECD on February 10 released public comments to three discussion drafts that propose to modify OECD transfer pricing guidelines in response to the OECD/G-20 base erosion profit shifting (BEPS) plan.
Eighty-three public comments were released that respond to a BEPS discussion draft issued December 19 on transfer pricing risk, recharacterisation, and special measures.
The draft proposes fundamental revisions to the OECD transfer pricing guidelines, seeking to provide a more accurate delineation of related party transactions, providing guidance on the relevance and allocation of risk, and requiring recharacterization of transactions in some cases.
Fifty-seven public comments were released on a paper on BEPS action 10 on the use of profit splits in the context of global value chains. In the draft, released December 16, the OECD announced that it is working on revising transfer pricing guidelines relating to the use of the transactional profit split method and requested feedback on issues associated with that project.
The OECD’s discussion draft on the transfer pricing aspects of cross-border commodity transactions, also released December 16, received 34 public comments. The draft proposes to modify OECD transfer pricing guidelines to clarify that the arm’s length price for commodities can be determined by reference to a commodity’s quoted or publicly available prices. The guidance also sets the shipment date as the default pricing date.
A public consultation on all three drafts will be held March 19-20 at OECD headquarters in Paris. The meeting will be webcast live.
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