The Organisation for Economic Co-operation and Development (OECD) Council approved the Revised Section E on safe Harbours in Chapter IV of the Transfer Pricing Guidelines, on 16th May 2013.
The Revised Section E (Section E) contains only nine pages, providing mostly suggestions and guidance for tax authorities evaluating the benefits and concerns regarding safe harbour provisions. Section E suggests that tax authorities take special care on the adoption of safe harbours, especially unilateral safe harbours. The revised section E advises that bilateral or multilateral safe harbours negotiated between Competent Authorities may be the best route if safe harbours are adopted, and provides examples of Memoranda of Understanding that could be used as the basis of bilateral or multilateral agreements.
