The Platform for Collaboration on Tax – a joint initiative of the International Monetary Fund (IMF), Organisation for Economic Co-operation and Development (OECD), United Nations (UN) and World Bank Group (WBG) – on 24 January 2017, released a draft toolkit addressing ways that emerging economies can overcome lack of comparable data or market prices for goods and services in the area of transfer pricing. The ‘Platform’ has asked for comments and input on the draft by 21 February 2017 from interested stakeholders to finalise the toolkit. Responses can be sent in through the Secretariats of the four organisations involved.
The toolkit is a very insightful document which simplifies and addresses some of the challenges associated accessing comparables data (for benchmark studies). It also focuses on how to make the best use of available data and on the importance of the choice of the most appropriate transfer pricing method.
Further, it describes issues and possible solutions when adequate data on transactions between independent parties are not available, including the potential for developing safe harbours or prescriptive approaches. Finally, due to the complexity of the topic, the toolkit sets out areas where further work is planned, and summarises a number of conclusions.