The US Multistate Tax Commission (MTC) has announced it aims to launch an interstate transfer pricing (TP) audit programme in July 2015. The move was brought on by Michael Bryan, director of the New Jersey Division of Taxation, challenging the commission to create a dedicated TP audit programme or risk a coalition of states creating their own.
The Treasury recently announced its support for a planned revamp of global tax rules which it warned would not always result in increased UK revenues or taxing rights. This has led many in the tax industry to worry about the pressure the OECD is placing on the UK to tighten its tax regime in ways that could undermine foreign investment in the country.
New proposals for APA and MAP applications, released during the last quarter of 2013, reflect changes in the advance pricing and mutual agreement programme’s (APMA) structure. The proposals emphasise a desire to resolve as many tax issues as possible in one procedural format.
The potential impact of the OECD’s BEPS project on indirect tax is a topic that has been overshadowed, with discussions focusing on intangibles and country-by-country Reporting (CBCR); however, it remains an important issue due to its strong links with transfer pricing (TP).
The OECD issued a revised draft of chapter V of the OECD guidelines on documentation in January, which placed emphasis on transfer pricing enquiry and risk assessment. Guidance on country-by-country reporting (CBCR) was one of the vital additions aimed at helping tax authorities with risk assessment. However, reactions have shown that, in its current state, CBCR may not be feasible.
At a recent conference in Paris, the OECD’s Joe Andrus, director of transfer pricing, discussed the results of Working Party 6 deliberations and announced the alterations that will be made to country-by-country reporting (CbCR) guidelines as a result of feedback from the tax industry.
