6 June 2012 - The OECD Secretariat invites public comments on certain timing issues related to transfer pricing, in connection with the work of Working Party No. 6 on intangibles and other projects.Modifications to the Transfer Pricing Guidelines on these issues have been discussed by Working Party No. 6 delegates.Those modifications are not agreed by all countries. However, they raise certain difficult issues on which comment by the business community is specifically requested by the Secretariat.
The paragraphs under consideration highlight the fact that OECD member countries follow two different approaches in applying the arm’s length principle. The existence of these different approaches to applying the arm’s length principle raises a number of difficult issues.It would be helpful to the Secretariat to have comments on the practical problems caused by the existence of these two different approaches.
Interested parties are invited to send comments on this discussion draft before 14 September.Comments should be sent in Word format to Mr. Joe Andrus, Head, Transfer Pricing Unit (email@example.com). Unless otherwise requested at the time of submission, comments received may be posted on the OECD website.
Depending on the nature of the comments received, there may be a public consultation on the matters that are subject to this request during the week of 5 November 2012.Participants in the public consultation will be drawn primarily from those providing timely written comments.
Section 240A of the Tax Administration Act, 2011 (as amended) requires that all tax practitioners register with a recognized controlling body before 1 July 2013. It is a criminal offense to not register with both a recognized controlling body and SARS.