The OECD has published the comments it received for each of its recent BEPS transfer pricing papers, and followed this up with a podcast last week confirming the G20 endorsement of country by country reporting. The arm’s length principle is to be strengthened, and concerns over whether the intra-group outsourcing of routine activities would still be possible were addressed. Following the UK’s lead, Spain confirmed that it would both be implementing country by country reporting in line with BEPS, and changed its transfer pricing rules. Meanwhile, the US government has proposed measures to limit the ability of domestic entities to expatriate, and Singapore has updated the transfer pricing part of its online Tax Guide.
