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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.
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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”.
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.
A Business Advisory Group was created to provide input from the business community at the early stages of the work on Business Restructurings.
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
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.