OECD base erosion and profit shifting project - update on transfer pricing issues

Tax Controversy & Dispute Resolution ()

The Organisation for Economic Co-operation and Development (OECD), on February 12, 2013, issued its initial report regarding Base Erosion and Profit-Shifting (BEPS). Since its release, there have been several discussions between the OECD working group, representatives from different tax authorities and the business. The BEPS report and the subsequent discussion has created speculation as to where the key area of focus could land. The discussions seem to have distilled the key pressure areas to control of risks and intangibles, use of hybrids, taxation of digital business, transparency agenda, inter-group financial transactions and anti-avoidance measures. The key issues are expected to be addressed by the Comprehensive Action Plan (CAP) which is due to be issued in July.