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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
On 10 May 2006, the OECD released a series of draft issues notes on comparability that was developed by the Committee on Fiscal Affairs' Working Party No. 6, building on experience acquired by countries since the adoption of the Transfer Pricing Guidelines in 1995 and on comments received from the business community in response to an open questionnaire release in 2003.
The 2nd joint conference provided a discussion forum to explore ideas for bridging the gap between direct and indirect taxation on the valuation of transactions between related parties, as well as possible areas for strengthening coordination between customs and tax specialists.
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The purpose of this note is to share information concerning the strategies employed by a number of selected revenue bodies to improve the efficiency and effectiveness of indirect measurement methods used to validate and to establish taxpayers’ tax liabilities in the course of tax audit activities. The note summarises the results of a short survey conducted in selected countries on their use of indirect income measurement methods, with
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The purpose of this note is to report the findings, observations and international comparisons derived from a survey of auditor workforce management approaches adopted in selected OECD countries. The survey, conducted over the last year and involving some 10 member countries, explored a range of matters, including: 1) identifying the required capabilities of auditors and audit managers; 2) methods for assessing auditor capability; 3)
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This information note focuses on audit programmes and the conduct of individual audits. It identifies common key features of audit activity found in a wide variety of tax administrations and outlines the principles underpinning these characteristics. The note does not purport to be an authoritative and comprehensive guide on how audit activities should be conducted. Rather, it draws together information provided by member countries
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The OECD's project on Harmful Tax Practices: 2006 Update on Progress in Member Countries