The tax seminar on ‘BEPS: Transfer Pricing Documentation, Risk Assessment and Safe Harbours’ has been held in Jeju Island, Korea from 26th to 31st October in 2015.

This event has aimed at discussing the new guidance on transfer pricing documentation and country-by-country reporting (“CbC reporting”), the draft handbook on transfer pricing risk assessment as well as the revised guidance on safe harbours.

The revised guidance on safe harbours provides opportunities for countries, especially developing countries, to design a transfer pricing compliance environment that makes optimal use of the limited resources available.

It encourages, under the right circumstances, the use of bilateral or multilateral safe harbours as they may provide a significant relief from compliance burdens without creating problems of double taxation or double non-taxation. The design and development of a bilateral safe harbour on the basis of an MOU has also beend discussed during the event.

The topics of this seminar include

 – Review of the arm’s length principle, comparability and transfer pricing methods

 – New guidance on transfer pricing documentation and country-by-country reporting

 – Transfer pricing risk assessment

 – Low value-adding intra-group services

 – Unilateral and bilateral safe harbours.

Participants has been given the opportunity to make presentations on their own experiences and specific problems encountered in the area of transfer pricing documentation, risk assessment and safe harbours. 

Tax Programme, OECD Korea Policy Centre