The OECD will lead a guidance project designed to help tax administrations determine the price of mineral commodities for transfer pricing purposes as a part of its effort to address the tax avoidance concerns of developing nations, a September report prepared by the OECD Secretary-General to G20 Finance Ministers said.
The project is one of several being undertaken by the OECD to fulfill a G20 Development Working Group mandate, announced September 2014, requiring the OECD provide practical support to developing nations on base erosion profit shifting (BEPS) issues.
The work will supplement a project already underway to develop a practical toolkit to help nations deal with the difficulties of finding comparable data for use in transfer pricing assessments. The project, being undertaken jointly by the OECD, World Bank Group, IMF, and UN, is expected to be complete in October 2016, the OECD said.
According to the report, other work to be carried out in 2016–17 to fulfill the G20 working group mandate includes:
- A report on the issues arising from the indirect transfer of assets, to identify policy options to tackle abusive cases, with particular reference to developing countries;
- A toolkit on the assessment of BEPS risks, focusing on high-risk or significant industry sectors;
- A toolkit to support the implementation by developing countries of effective transfer pricing documentation requirements;
- A toolkit aimed at strengthening capacity for effective tax treaty negotiations;
- A toolkit to support countries seeking to implement rules to address base eroding payments between MNE affiliates, in particular with respect to payments of interest, royalties, management and service fees; and
- A toolkit on the development of rules to counter artificial profit shifting through supply chain restructuring.
The OECD Secretary General reported that a second round of regional network meetings will take place in October, to be attended by representatives of more than 80 countries gathering at 5 locations. Meeting attendees will provide input on the OECD’s preliminary work undertaken to fulfill the G20 working group mandate and will consider how to best to meet the challenge of implementing the final OECD/G20 BEPS output.
See:
Related MNE Tax Articles
Be the first to comment