• Service: Tax, Global Transfer Pricing Services
  • Type: Regulatory update
  • Date: 3/12/2014

OECD - Transfer pricing comparability data and developing countries 

March 12:  The Organisation for Economic Co-operation and Development (OECD) was requested by the G8 at its Lough Erne Summit “…to find ways to address the concerns ... on the quality and availability of the information on comparable transactions that is needed to administer transfer pricing effectively.

As noted in the OECD release, a paper (prepared by the OECD in conjunction with the Task Force on Tax and Development) sets out 15 possible actions under four headings:

  • Expanding access to data sources for comparables including steps to improve the range of data in commercial data bases
  • More effective use of data sources for comparables including guidance on the selection of foreign comparables and how to make appropriate adjustments
  • Approaches which don’t rely on direct comparables including profit split methods, supply chain analysis and an interesting discussion of the “sixth method” involving the use of spot commodity prices gaining prevalence in Latin America and Africa
  • Greater use of advance pricing agreements and mutual agreement proceedings

Read text of the OECD paper [PDF 158 KB].

Comments are due by 11 April 2014.

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

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