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Indian tax official sees expanded role for BEPS inclusive framework, addresses transfer pricing local file
October, 19th 2016

The countries that have joined the inclusive framework established to carry out the work of the OECD/G20 base erosion profit shifting (BEPS) project are likely to eventually take on international tax work outside of the BEPS project, an Indian tax official said this week.

The official also addressed the contents of India’s transfer pricing local file and discussed Indian and US tax officials’ progress resolving mutual agreement procedure (MAP) and advance pricing agreement (APA) disputes.

The inclusive framework, established this year by the OECD and G20 to ensure widespread adoption of the BEPS plan output, is now comprised of over 100 countries and jurisdictions. These countries collaborate and monitor the implementation of the BEPS package and also participate in the international tax standard setting work remaining in the BEPS project, including work on transfer pricing and tax treaties.

According to Indian IRS officer, Akhilesh Ranjan, with so many countries joining in, framework appears to be increasing in importance. Ranjan said it seems likely that the countries involved may one day want to address issues that are important but not addressed by the BEPS project.

“I see it moving on beyond BEPS at some stage,” said Ranjan, who spoke to Taxsutra group editor, Arun Giri, during a webcast interview on the sidelines of the IFA Madrid Congress, held September 25–30.

Ranjan added that the G20’s relevance as the setter of international tax standards is increasing day by day. The G20 is the only forum that is leading the tax initiatives, and its membership includes the right balance of different types of economies, Ranjan said.

Marketing intangibles

Turning to the BEPS standards on transfer pricing documentation, Ranjan said that his office will recommend that the Indian government include in India’s transfer pricing local file a requirement that multinationals provide information about marketing intangibles.

India views marketing intangibles to be very relevant to transfer pricing, and thus it seems appropriate to require information in the local file that allows tax officials to assess whether there are arrangements that create or develop them, he said.

US disputes

Responding to questions from Mukesh Butani, managing partner of BMR Legal, Ranjan said the US and India have made “tremendous progress” in MAP cases, recently resolving between 110-120 cases, with “more in pipeline.”

Ranjan said the US and India have begun to talk about cases that go beyond transfer pricing, addressing tax treaty issues and other topics.

He added that the opening in India of a bilateral APA program has created manpower challenges. India wants the APA process to move more quickly, he said.

Robert Stack, Treasury deputy assistant secretary (International Tax Affairs) agreed that there have been recent successes in US-Indian relations regarding taxation.

Stack noted though, that many difficult MAP and APA cases are still pending. “It is in everybody’s interest to find a compromise,” Stack said.

“I know how much India is trying to focus on creating an environment to support investment and I think they are working very hard on it and are making great strides,” Stack said.

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