On September 16, the OECD published the first set of recommendations in connection with its Base Erosion and Profit Shifting (BEPS) action plan. The published papers address some elements of the action plan including: Neutralising the effect of Hybrid mismatch arrangements; Preventing the Granting of Treaty Benefits in inappropriate circumstances; Countering Harmful Tax Practices More Effectively, Taking into Account Transparency and Substance; Feasibility of Multilateral instruments and Addressing the Tax challenges of the digital economy.
Two other published papers are in respect of revisions to the OECD Transfer Pricing (TP) guidelines of 2010 regarding TP Documentation, Special considerations for intangibles, Arm’s Length Principle and TP Methods.
The changes will have implications for Nigerian taxpayers because the Nigerian TP regulations are to be applied in line with the provisions of the OECD guidelines as may be updated from time to time.
Read our tax alert uploaded below for an overview of the changes and a summary of the issues covered in the other reports released by the OECD.