Transactional profit methods : discussion draft for public comment

As part of its monitoring of the implementation of the 1995 Transfer Pricing Guidelines, Working Party No. 6 of the OECD Committee on Fiscal Affairs is examining the application of transactional profit methods.<

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Discussion draft released on Part IV (Insurance) of Report on Attribution of Profits to Permanent Establishments (revised)

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.

Meeting the Challenges posed by Business Restructurings: The OECD Response

Presentation by Jeffrey Owens, Director, Centre for Tax Policy and Administration for the OECD/BIAC Conference held in Stockholm on 28/29 May 2007.

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WCO-OECD conference, 22-23 May 2007

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Approval of a mandate for the Joint Working Party No. 1 - Working Party No. 6 Working Group on Business Restructuring, 20 October 2006

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.

Business advisory group to the Joint Working Group on business restructurings

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Manual on Effective Mutual Agreement Procedures (MEMAP)

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).

Guidelines on Advance Pricing Arrangements

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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Comparability: Business comments on the OECD discussion draft

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.