OECD and Transfer Pricing Experts Discuss New Draft

OECD and Transfer Pricing Experts Discuss New Draft

The Organization for Economic Cooperation and Development (OECD) recently held a meeting with transfer pricing experts from governments and private sector representatives for discussing transfer pricing issues indicated in the report “Intangibles, Safe Harbors and Timing Issues” published in June.

The OECD received almost 1,400 pages of comments on these issues, including 132 comment letters from business representatives. The discussions were held over two and a half days and Focused mainly on the following topics:

- Possible ways of simplifying transfer pricing compliance and enforcement, provisions for a simple set of prescribed transfer pricing rules that already have been introduced by a number of countries and mainly benefit small taxpayers in respect of less complex transactions.

- Approaches for clarifying transfer pricing rules for transactions involving intangibles, including rules aimed at limiting the opportunities for using transfer of intangibles for obtaining a tax advantage by attributing income to parties that only hold the legal title to the intangible without economically contributing to its development or maintenance.

The OECD Committee on Fiscal Affairs due to release a revised discussion draft and, probably, final guidance on some of those provisions in 2013.

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