• Service: Tax, Global Transfer Pricing Services, International Tax
  • Type: Regulatory update
  • Date: 2/14/2014

OECD - Questions presented by transfer pricing documentation, country-by-country reporting 

February 14:  The Organisation for Economic Co-operation and Development (OECD) on 30 January 2014 released an initial draft of revised guidance on transfer pricing documentation and country-by-country reporting pursuant to Action 13 under the Base Erosion and Profit Shifting (BEPS) Action Plan.

The OECD provided a short (three weeks) window for comments before the consultation closes on 23 February 2014.

When the OECD decides something in the international tax world needs updating, it typically launches a “project” among its members, brings in business input, and then issues a discussion draft. After a period of consultation and some internal debate, a revised version then appears as a formal commentary or chapter. The process often takes years. Not this time.

The BEPS initiative has “turbocharged” things so much that this discussion draft (the outcome of Action 13 on the BEPS action plan) has arrived in a little over six months.

It is worth being reminded as to what is behind the new document. Faced with squeezes on public finances and widespread media coverage of multinational corporations “squirreling away” profits in low tax locations, governments in the world’s major markets have decided something must be done. To address the issue, they feel they need greater visibility of what the problem is.

Accordingly, country-by-country reporting and changes to transfer pricing documentation have been initiated to help them.

Now that the discussion draft has been published, the questions being asked are:

  • Will the proposals achieve what they set out to achieve?
  • Is the extra compliance burden on companies reasonable or excessive?
  • How can the final guidelines be improved to make sure both of the above are achieved?

Read a February 2014 report [PDF 106 KB] provided by KPMG International that addresses these questions: The OECD discussion draft on transfer pricing documentation and country by country reporting: 3 weeks to have your say

Contact a tax professional with KPMG's Global Transfer Pricing Services.

©2014 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. All rights reserved.

The KPMG logo and name are trademarks of KPMG International.

KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever.

The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.

Direct comments, including requests for subscriptions, to
For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at:

+ 1 202 533 4366

1801 K Street NW
Washington, DC 20006.


Share this

Share this


Subscribe to receive the latest TaxNewsFlash email alerts (you must select the option for TaxNewsFlash)

Already a Subscriber? Login

Not a member? Subscribe now