As part of its procedures for monitoring the implementation of the 1995 Transfer Pricing Guidelines, Working Party No. 6 of the Committee on Fiscal Affairs has selected two areas to be considered in priority:

• Comparability analysis when applying the transfer pricing methods authorised by the 1995 Transfer Pricing Guidelines (whether traditional transaction methods or transactional profit methods) and
• The application of transactional profit methods (i.e., the profit split methods and the transactional net margin method which are described in Chapter III of the 1995 Transfer Pricing Guidelines).

It is expected that the ultimate outcome of these reviews should be a revision of Chapters I and III of the 1995 Transfer Pricing Guidelines.

We believe it is essential for our work to benefit from input from the business community and from other interested non-governmental parties. In April 2003, the public was invited to comment on issues in relation to comparability (see invitation to comment and comments received). The Working Party has been working on a series of Issues notes that was released for public comment in May 2006.

Comments on issues related to profit methods were invited from the Business and Industry Advisory Committee (BIAC) and an open invitation to contribute on a number of issues in relation to transactional profit methods was released in February 2006 (see contributions received).