STUDY ON THE FEASIBILITY OF INTRODUCING TRANSFER PRICING UNILATERAL OR BILATERAL SAFE HARBOURS PROVISION IN ECOWAS COUNTRIES

To provide technical input to the European Commission on the feasibility for developing countries to increase domestic revenue mobilisation, in particular on issues linked to transfer pricing, and in accordance with international tax principles including the minimum standards of good governance in tax matters (transparency, exchange of information and fair tax competition).
This study is also linked to EU efforts in the frame of the tripartite initiative (OECD/WB/EU) on transfer pricing.A safe harbour substitutes simpler obligations than those under the general transfer pricing rules. Such a provision could, for example, allow taxpayers to establish transfer prices in a specific way, e.g. by applying a simplified transfer pricing approach provided by the tax administration. Alternatively, a safe harbour could exempt a defined category of taxpayers or transactions from the application of all or part of the general transfer pricing rules. Often, eligible taxpayers complying with the safe harbour provision will be relieved from burdensome compliance obligations, including some or all associated transfer pricing documentation requirements.