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TP Ticker – September 2018

Comments on the Discussion Draft on Financial Transactions

On 14 September 2018, the OECD published the comments received from external parties on their discussion draft on the transfer pricing aspects of financial transactions.  The draft is part of the OECD’s follow-up on BEPS Action 8-10 aiming at assuring that transfer pricing outcomes are in line with value creation.  The comments are collected in three reports, together amounting to more than 800 pages and contain input from advisors, researchers, and taxpayers.  Our own comments are contained in Part 1.

The three reports containing the comments on the discussion draft on financial transactions are available on the website of the OECD here: https://www.oecd.org/ctp/transfer-pricing/public-comments-received-on-beps-discussion-draft-on-the-transfer-pricing-aspects-of-financial-transactions.htm

New Transfer Pricing Country Profiles

On 7 September 2018, the OECD updated its website on Transfer Pricing Country Profiles. This update includes new profiles for seven jurisdictions – Costa Rica, Greece, South Korea, Panama, Seychelles, South Africa, and Turkey – and an update of the country profile for Singapore. These country profiles are collected by the OECD in the form of surveys made with the respective tax administration of the covered jurisdictions. They contain a detailed overview about the legal and regulatory basis for transfer pricing and the viewpoints of the tax administration in the respective jurisdiction in a standardized format. Therefore, they provide an easy and reliable means of confirming the requirements in a specific jurisdiction. With this update, the OECD’s country profiles cover 52 tax jurisdictions worldwide.

The announcement of the update can be found on the website of the OECD here: https://www.oecd.org/tax/transfer-pricing/oecd-releases-seven-new-transfer-pricing-country-profiles-and-an-update-of-a-previously-released-profile.htm

The Transfer Pricing Country Profiles are available online here: https://www.oecd.org/ctp/transfer-pricing/transfer-pricing-country-profiles.htm