Further discussion drafts are to be issued in May 2015 as part of the OECD/G20 action plan on base erosion and profit shifting (BEPS).

A discussion draft on cost contribution arrangements is planned for around the end of April 2015. This is part of the work on BEPS actions 8 to 10 relating to transfer pricing issues. The work on cost contribution arrangements would lead to changes to Chapter VII of the OECD transfer pricing guidelines.

A revised discussion draft on BEPS action 6 on abuse of tax treaties is planned for 15 May 2015. This action deals with ways of combating artificial tax avoidance through treaty shopping. A revised discussion draft on BEPS action 7 on combating artificial avoidance of permanent establishment status is also due around 15 May 2015. The deadline for submission of comments on these revised discussion drafts will be around 30 days after their release date.

A further discussion draft relating to BEPS actions 8 to 10 is to be issued around the end of May 2015. The discussion draft will deal with revisions to chapters I and VI of the OECD transfer pricing guidelines to strengthen the provisions on risks, non-recognition of transactions and intangibles. The deadline for submission of comments on this revised draft is to be set at only 14 to 21 days after its release.

The OECD is holding public consultations during May 2015 on BEPS action 12 (disclosure rules); BEPS action 3 (CFC rules); and BEPS action 11 (data analysis).

The deadline for submission of information in respect of the OECD/ World Bank transfer pricing survey on country experiences in accessing and using comparability data is 3 May 2015.

The OECD is also to hold a webcast on 8 June 2015 to give an update on the progress of the BEPS action plan. There will be public consultations on BEPS actions 8 to 10 around the end of June and early July 2015, dealing with revisions to chapter I of the OECD transfer pricing guidelines (risks and non-recognition); Chapter VI (intangibles including hard to value intangibles); and Chapter VIII (cost contribution arrangements).