The Platform for Collaboration on Tax, a joint initiative of the IMF, OECD, UN and World Bank Group, issued a draft toolkit in October 2019 designed to help developing countries in the implementation of effective transfer pricing documentation requirements. Input on the draft toolkit was due by 8 November 2019. The Global Tax Advisers Platform, of which CFE Tax Advisers Europe is a founding member, was pleased to submit a response.
The consultation sought specific input concerning: whether the draft toolkit addresses all the relevant considerations for the design of an effective transfer pricing documentation regulatory system; whether particular approaches (e.g. penalties or compliance incentives) are especially beneficial for limited capacity developing countries, in terms of enforcement of transfer pricing documentation; whether there other transfer pricing documentation requirements not covered in this toolkit that should be considered; and what additional considerations and/or tools can be included to assist developing countries to implement effective transfer pricing documentation.
GTAP welcomed the draft toolkit, and set out its view that the toolkit has significant potential impact in terms of developing uniformity in practice across jurisdictions. GTAP’s responses to the consultation questions were based on responses compiled by fellow founding GTAP member, the West African Union of Tax Institutes and its member organisation, the Chartered Institute of Taxation of Nigeria (CITN).
We invite you to read the response below.