Commenting on the OECD’s discussion draft on Transfer Pricing Documentation and Country by Country Reporting published today, Jane McCormick, KPMG’s UK head of Tax and Pensions said:
“Today’s discussion document shows how much progress can be made with real political impetus. The OECD’s BEPS (‘Base Erosion and Profit Shifting’) initiative is a once in a lifetime opportunity for governments to change the international tax landscape and businesses must play their part by engaging fully.
“We welcome the opportunity to take part in the consultation on the discussion draft. Echoing the words of last week’s OECD webcast, time for the consultation is short – comments must be submitted in writing on or before 23 February 2014.
“Over the next three weeks, we urge businesses and other interested parties, as well as the OECD, to participate actively and constructively in the debate to ensure that the final guidance achieves the objectives set out in Action 13 of the OECD’s BEPS Action Plan which, broadly, are to develop rules in relation to transfer pricing documentation that enhance transparency for tax administrations whilst taking into account the compliance costs for business.
“At first glance, much of what is being suggested on transfer pricing documentation looks to be in line with the best practice that many of our multinational clients are currently implementing. In relation to Country by Country Reporting, businesses will be concerned about the potential compliance burden particularly given the proposals to report cross border payments between companies in the group and withholding taxes. It is imperative that businesses engage now on the key questions raised in the draft such that whatever is finally agreed provides tax authorities with the relevant information they need, yet does not place an unreasonable burden on companies. We note that the OECD has made reference to materiality and risk assessment in the discussion document – this will be an important feature in ensuring that the new requirements are balanced and properly targeted.”
Further information about the OECD’s BEPS initiative is available on the OECD’s website:http://www.oecd.org/ctp/beps.htm
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This article represents the views of the author only, and does not necessarily represent the views or professional advice of KPMG in the UK.