Daily Tax Update - December 16, 2014: OECD Releases Discussion Drafts

OECD Releases Discussion Drafts on Transfer Pricing and Profit Splits:  As part of its work in relation to Base Erosion and Profit Shifting (BEPS), the OECD issued two discussion drafts and is requesting public comment.  The Discussion Draft on the Transfer Pricing Aspects of Cross-Border Commodity Transactions provides proposals relating to the application of transfer pricing rules to commodity transactions.  The Discussion Draft on the Use of Profit Splits in the Context of Global Value Chains looks at specific scenarios to address questions regarding the appropriate use and application of transactional profit split methods for transfer pricing.

IRS Updates List of Jurisdictions With Information Exchange Agreements:  Revenue Procedure 2014-64 provides the updated list of jurisdictions with which the United States has agreements relating to the exchange of information for purposes of bank interest reporting requirements.  The Revenue Procedure also identifies the jurisdictions with which the automatic exchange of information has been determined to be appropriate.