The Platform for Collaboration on Tax (PCT) – a joint initiative of the International Monetary Fund (IMF), Organisation for Economic Co-operation and Development (OECD), United Nations (UN) and World Bank Group – published several toolkits, which contain practical guidance for countries to better protect their tax base in the context of transfer pricing. This toolkit, "Addressing Difficulties in Accessing Comparable Data for Transfer Pricing Analyses" is available here.
The toolkit specifically addresses the ways the countries can overcome a lack of data needed to implement transfer pricing rules. This data is needed to determine whether the prices the enterprise uses accord with those which would be expected between independent parties. The guidance may also help countries set rules and practices that are more predictable for business.
Since the pricing of transactions between related parties in the extractive industries is an issue of particular relevance to many developing countries, the toolkit in its Annex also addresses the information gaps on prices of minerals sold in an intermediate form. During the event, a range of practical examples and case studies will be provided to illustrate the toolkit. Participants will also be able to discuss their practical experience as well as challenges that they face and also their experience with the practical approaches to delineating the transaction and undertaking a search for potential comparables and also the possible approaches to carrying out comparability adjustments.
The event is also aimed to provide possible approaches to enable greater practical implementation of transfer pricing regimes that apply the arm’s length principle, in accordance with the realities faced by participating countries, including limited information availability and administrative capacity. In addition, the event will show different policy options that countries could consider, together with some additional initiatives that could be taken on by countries, or international or regional organisations to more systematically mitigate the problems caused by poor availability of or access to relevant data.