On 16 May 2013, the OECD approved the revision of Section E on safe harbours in Chapter IV of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (TPG). The OECD said the new guidance on safe harbours provides opportunities for countries to relieve some compliance burdens and to provide greater certainty for cases involving smaller taxpayers or less complex transactions. With that, it provides a basis for countries, especially developing countries, to design a transfer pricing compliance environment that makes optimal use of the limited resources available.

The OECD said the previous guidance in the TPG had a somewhat negative tone regarding transfer pricing safe harbours. This negative tone did not accurately reflect the practice of OECD Member countries, a number of which have adopted transfer pricing safe harbour provisions.

[LTN 100, 27/5/13]