As part of the 19 July 2013 Base Erosion Profit Shifting (BEPS) Action Plan, the OECD has published an initial draft of revised guidance on transfer pricing documentation and country-by-country reporting, for comment by 23 February 2014.

The draft reflects limited consideration of the issues in the short time since the publication of the Action Plan and seeks to identify issues for public comment.

Issues on which comments have been invited include whether work on BEPS Action 13 should include development of additional standard forms and questionnaires beyond the country-by-country reporting template.

The OECD has also asked for comment on the circumstances in which it might be appropriate for tax authorities to share their risk assessment with taxpayers, as well as the appropriate scope and nature of possible rules relating to the production of information and documents in the possession of associated enterprises outside the jurisdiction requesting the information.

In addition, it has called for comment around whether any more specific guideline on materiality could be provided and what form such materiality standards could take.

And it has requested suggestions as to the measures that could be taken to simplify the documentation process, and the measures that can be taken to safeguard the confidentiality of sensitive information without limiting tax administration access to relevant information.

The OECD also wants input on the most appropriate mechanism for making the master file and country-by-country reporting template available to relevant tax administrations.

The discussion draft is available HERE

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