This toolkit provides an analysis of and options for the tax treatment of Offshore Indirect Transfers (OITs).
A Medium Term Revenue Strategy (MTRS) is a high-level road map of the tax system reform over 4-6 years—its policy, administration, and legal components. It embodies a government's strategy to mobilize resources through a tax system that can finance its spending needs and secure macroeconomic sustainability, while reflecting distributional considerations and creating appropriate incentives for economic and social development.
This Concept Note describes the PCT Partners’ approach for the PCT workshops supporting the MTRS implementation.
This toolkit attempts to address some of the challenges associated with difficulties in accessing comparables data. While 'perfect' or ideal comparables may only rarely be available, commonly the data that is available will still allow a reasonably reliable analysis to be performed and a satisfactory approximation of an arm's-length outcome to be determined. Part II of this toolkit thus focuses on making the best use of available data.