OECD - Draft Handbook on Transfer Pricing Risk Assessment released

Tax Controversy & Dispute Resolution ()

On April 30, 2013, the Steering Committee of the OECD Global Forum on Transfer Pricing (Steering Committee) released a publication entitled “Draft Handbook on Transfer Pricing Risk Assessment” (the Handbook). The Global Forum on Transfer Pricing consists of all 34 OECD member countries, over 100 non-OECD countries, and nine international organizations, and is focused on the need to simplify transfer pricing rules, strengthen the guidelines on intangible issues and improve the efficiency of dispute resolution. The Steering Committee undertakes one project per year that is generally a ‘best practices’ overview of an important topic in transfer pricing administration that has relevance to both developed and developing economies.

The Handbook is meant to act as a supplement to prior OECD publications, including “Dealing Effectively with the Challenges of Transfer Pricing,” a report released in January 2012 which included a chapter discussing transfer pricing risk assessment. Recognizing the need for practical guidance on implementing risk assessment techniques, the Steering Committee of the OECD Global Forum on Transfer Pricing undertook a project on transfer pricing risk assessment in November of 2011. The goal of the project was to provide tax authorities with a practical Handbook that offered a framework for assessing the transfer pricing risk presented by an individual taxpayer’s operations. Interested parties are invited to provide comments on the Handbook by September 13, 2013.