IN a
presentation captioned 'BEPS Action Plan: Update on 2014 Deliverables', OECD
says that the project would finalize its report/stance on transfer pricing
especially intangibles by May 2014. It has already secured public comments
on the first and revised draft discussion on the subject.
As for transfer pricing documentation, the project is slated to release a discussion draft of Chapter V of the Transfer Pricing Guidelines, including a Country-by-Country reporting template.
The presentation dated 23 January 2014 says: Tax administrations need for "big picture' information" on the global value chain versus compliance burden on multinational enterprises (MNEs).
It has also disclosed that a task force constituted under the project is slated to finalize by September 2014 its report on tackling BEPS in the digital economy.
The project would also release a discussion draft on abuse of bilateral tax treaties in March 2014. It would also issue in April 2014 a discussion draft on 'hybrid mismatch arrangements' such as hybrid financial instruments or hybrid transfers that give rise to double deduction or a deduction with no matching inclusion.
OECD is also aiming to publish by September 2014 a report on harmful tax practices.
A report on feasibility of use of multilateral instruments to implement BEPS measures and amend bilateral tax treaties is proposed to be finalized by September this year. OECD admits that his subject bristle "several difficult issues" but believes that "none appears unsurmountable."
As explained by OECD, "BEPS arises because under the existing rules MNEs are often able to artificially separate the allocation of their taxable profits from the jurisdictions in which these profits arise."
Pointing out that most BEPS planning is legal, the presentation says: "if governments are unhappy with results, the rules should be changed."
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