Transfer pricing briefing for January 2015

The OECD has issued three transfer pricing papers for consultation as part of the BEPS process. The largest covers risk and the recharacterisation of transactions. The other two deal with profit splits and commodity transactions respectively. Guidance has become available on transfer pricing in Finland. The Czech Republic, where a court ruling suggests the burden of proof has shifted to the taxpayer, has introduced further reporting requirements. Korea is making simplifying measures available for smaller businesses