Consequent on the Action Plan, the OECD recently published a discussion draft (OECD Discussion Draft on Transfer Pricing Documentation and Country by Country reporting), which addresses BEPS Action Point 13. Comments on the document are due by 23 February 2014, while the deadline for completion of the OECD project is September 2014.
Follow the link to find a copy of the discussion draft.
- Proposed two-tiered approach, i.e. “Masterfile” and “Local File” documentation;
- Proposals regarding timing of submission of transfer pricing documentation to tax authorities;
- Proposed rules/suggestions for transfer pricing penalties;
- Proposal that transfer pricing files should be reviewed annually, and specific suggestions regarding when database searches need to be updated;
- Proposal for specific rules for non-material transactions; and
- Apparent focus on taxpayer compliance self-review.
Please do not hesitate to contact a KPMG Global Transfer Pricing Services Professional should you have any questions regarding the above or wish to provide comments.