The OECD’s proposed changes to its transfer pricing guidelines might prompt governments to push further into companies’ business activities, tax professionals say.
Documentation recommended by the organization to prove that a service between affiliates actually took place—call minutes, emails, internal memos, IT tickets—goes beyond what current guidelines suggest. Practitioners say tax agencies could receive the information and press for more in an audit.
The amount of new information could “make more questions,” said Frédéric Barat, a partner at Forvis Mazars in Paris.
The Organization for Economic Cooperation and Development’s June 1 proposal would update part of its guidelines for ...