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The OECD Committee on Fiscal Affairs has today published a revised public discussion draft of Part IV (Insurance) of its Report on the Attribution of Profits to Permanent Establishments. The revised draft replaces the original draft of Part IV released in June 2005.
The study into the role of tax intermediaries, set up by the Forum on Tax Administration (FTA) under the Seoul Declaration (and see also the terms of reference ), has made three additional draft working papers available.
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Presentation by Jeffrey Owens, Director, Centre for Tax Policy and Administration for the OECD/BIAC Conference held in Stockholm on 28/29 May 2007.
22-23 May 2007, the World Customs Organization (WCO) and OECD held a 2nd Joint Confertence on “Transfer Pricing and Customs Valuation of Related Party Transactions”.
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The purpose of this guidance note is to promote thinking among revenue bodies on the development of a channel strategy, a set of actions intended to achieve optimal usage of the various means (i.e. channels) for delivering services to taxpayers. The note provides ideas on developing such a strategy, based largely on the experiences of selected revenue bodies.
A Business Advisory Group was created to provide input from the business community at the early stages of the work on Business Restructurings.
The Committee on Fiscal Affairs created a Joint Working Group of Delegates from Working Party No. 1 on the Model Tax Convention and Working Party No. 6 on the Taxation of Multinational Enterprises.
The online Manual on Effective Mutual Agreement Procedures (MEMAP) makes available, to both tax administrators and taxpayers, basic information and best practices regarding the Mutual Agreement Procedure (MAP).
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The term 'Advanced Pricing Arrangements' (APA) refers to a procedural arrangement between taxpayer and tax administration intended to resolve potential transfer pricing disputes in advance. These guidelines intend to improve the consistency of application of APAs by providing guidance to tax administrations on how to conduct mutual agreement procedures involving APAs.
These Guidelines are also included in the Annex of the Transfer
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Acuerdo sobre intercambio de información en materia tributaria