The OECD’s discussion draft on transfer pricing documentation and country by country reporting

On 30 January 2014 the OECD released an initial draft of revised guidance on transfer pricing documentation and country by country reporting. The discussion draft was prepared in the context of revisions to Chapter V of the OECD’s Transfer pricing guidelines which addresses documentation. The effect of the discussion draft would be to replace the existing Chapter V with the text of the discussion draft and its annexes. This could result in major changes to a chapter which currently comprises only 29 paragraphs and nine pages – the discussion draft already contains 45 paragraphs and 12 further pages of new annexes.

The discussion draft does not necessarily reflect the consensus view of the OECD’s Working Party (WP) 6...