The OECD is holding a consultation on 19 May 2014 to consider transfer pricing documentation and country-by-country reporting. This follows the publication of a discussion draft in relation to the BEPS (base erosion and profiting shifting) Action 13.
This follows the release of the discussion draft on transfer pricing documentation and country by country reporting on 30 January 2014 and the receipt of comments on the discussion draft. The draft was issued as part of the action plan on base erosion and profit shifting (BEPS).
The OECD discussion draft proposes a two tiered approach to transfer pricing documentation. It sets out in detail the proposed contents of a transfer pricing master file and of a local file that could become the recommended method of keeping transfer pricing documentation. The master file would contain details of the organization, business operations and assets of the multinational group of which the local taxpayer is a member, while the local file would contain details of the local entity and its controlled transactions.
