In January 2021, the OECD has released the document “Practical Toolkit to Support the Successful Implementation by Developing Countries of Effective Transfer Pricing Documentation Requirements”. The work represents output of The Platform for Collaboration on Tax, which is formed by the International Monetary Fund (IMF), the Organisation for Economic Co-operation and Development (OECD), the United Nations (UN), and the World Bank Group (WBG).
The Toolkit document seeks to link the OECD’s approach on transfer pricing perspectives with the specific situations affecting the so-called developing countries. The paper addresses price setting issues related to the arm’s length principle, the robustness of rules and provisions of documentation, and the standardized approach on the transfer pricing documentation such as the Master File, the Local Files, and the Country-by-Country reporting. The Toolkit also addresses documentation issues such additional information necessary to be filed with the tax returns and the questionnaires used by tax jurisdictions.
Information on practical applications: info@GlobalTransferPricing.com