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OECD discussion draft on Action 10 (transfer pricing aspects of cross-border commodity transactions) of the BEPS Action Plan
On 16 December 2014, the OECD published a discussion draft on Action 10 (transfer pricing aspects of cross-border commodity transactions) of the BEPS Action Plan. The Action Plan recognises that the actions to counter BEPS must be complemented with actions that ensure certainty and predictability for business. Taxand is honoured to provide combined feedback from around the world on the OECD discussion draft with respect to Action 10 of the BEPS Action Plan.
Action 10 of the BEPS Action Plan identifies that work needs to be undertaken to develop 'rules to prevent BEPS by engaging in transactions which would not, or would only very rarely, occur between third parties', which involves adopting various transfer pricing rules or special measures.
Taxand agrees that protecting the tax base of commodity dependent countries through ensuring that the transfer pricing outcomes of commodity transactions reflects value creation is in line with the objectives of the BEPS Action Plan, which we support.
Taxand is honoured to provide written comments to assist the OECD in their work on Action 10 based the practical experience we have as tax advisors and transfer pricing specialists.
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