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On 27 February 2006 the OECD released an open invitation to comment on a number of issues in relation to transactional profit methods described in the OECD's Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. Numberous contributions have now been received and will be carefully examined by Working Party No. 6 on the Taxation of Multinational Enterprises.
First joint WCO/OECD Conference on Transfer Pricing and Customs Valuation in Brussels on 3-4 May 2006.
An invitation to comment on a series of draft Issues notes 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 invitation to comment on comparability issues in 2003.
The OECD is now issuing an open invitation to contribute on a number of issues in relation to transactional profit methods. As part of its procedures for monitoring the implementation of the 1995 Transfer Pricing Guidelines (“the 1995 TP Guidelines”), Working Party No. 6 of the OECD Committee on Fiscal Affairs selected the area of application of transactional profits as one of two areas to be considered in priority.
The aim of the online manual is to make available, to both tax administrators and taxpayers in the OECD's Member countreis and non-OECD member countries, basic information and best practices regarding the Mutual Agreemetn Procedures (MAP) process. The goal is to make this information as accessible as possible and to allow users to understand the MAP process in a general but practical context.
Public Consultation Meeting on Recent OECD Initiatives to Improve International Tax Dispute Settlement Procedures, 13 March 2006, in Tokyo.
The OECD’s Centre for Tax Policy and Administration (CTPA) is organising a consultation with business on Part IV (Insurance) of the Discussion Draft on the Attribution of Profits to Permanent Establishments. That meeting will take place on Friday, 31 March 2006, in Paris at the OECD office
Further to the posting on 27 January 2005 the CFA has now released for public comment a discussion draft of the 4th and final part of its Report on the Attribution of Profits to a Permanent Establishment . Part I of the Report deals with general considerations, Part II deals with traditional banking, Part III deals with global trading and Part IV deals with insurance.
New communication technologies and the worldwide spread of the Internet have prompted the appearance of new business models and have changed the ways in which almost any business is conducted. The increased speed and mobility of business activities and cross-border transactions has particular implications for applying transfer pricing methods and for taxing business profits. E-commerce: Transfer Pricing and Business Profits presents
A summary note of the 2nd Annual CTPA Roundtable which took place on January 26-27, 2005 and which focused on the tax implications of cross-border business restructuring.