On October 6, 2014, TEI submitted comments to the Inland Revenue Authority of Singapore in response to an invitation for public comment on proposed rules governing transfer pricing documentation. Notable among its comments, TEI expressed concern that the proposed rules elevate Singapore’s transfer pricing documentation requirements to a higher level than those existing under the OECD transfer pricing guidelines ahead of final recommendations from the OECD’s base erosion and profit shifting (BEPS) project.
On September 30, 2013, TEI submitted a letter to the OECD commenting on its White Paper on Transfer Pricing Documentation. TEI’s comments focused on the need to reduce the transfer pricing documentation and compliance burden on taxpayers by standardizing requests for such documentation across tax authorities.
The comments were prepared under the aegis of TEI’s European Direct Tax Committee, whose chair is Alexander Kölbl of General Dynamics. Benjamin R. Shreck, TEI Tax Counsel, coordinated the preparation of TEI’s letter.
On March 4, 2013, TEI submitted a memorandum to the Multistate Tax Commission (MTC) urging it to abandon a proposed project aimed at creating model regulations governing the use of state statutory authority to adjust income and expenses between related parties (i.e., transfer pricing).