OECD has initaited a project on the administrative aspects of transfer pricing
aimed at striking an equilibrium between the development of sophisticated
guidance for complex transactions and the cost-effective use of taxpayers’ and
tax administrations’ resources for improved compliance and enforcement
processes.
The
project includes the following:
+ A
survey is currently being conducted of the administrative simplification
measures that countries have developed in the transfer pricing area. These
include safe harbours as well as other types of measures such as alleviated
documentation requirements for small transactions or small and medium sized
enterprises, streamlined dispute prevention processes, etc. The survey covers
OECD member countries as well as regular Observers to the Committee on Fiscal
Affairs;
+ An Internet-based platform for transfer pricing administration
was developed by the OECD to facilitate the sharing of information and
experience among tax officials on the administrative aspects of transfer
pricing, including issues such as the organisation of transfer pricing audits,
the development of risk assessment techniques, the design of transfer pricing
documentation requirements, the setting up of Advance Pricing Arrangement
programmes, etc;
+ the OECD is reviewing the existing guidance on safe
harbours in Chapter IV of the OECD Transfer Pricing Guidelines (“TPG”) with a
view to updating it in order to reflect the experience acquired since
1995.
The OECD has invited comments from interested parties.
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