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A large share of world trade consists of transfer of goods, intangibles and services within multinational enterprises. To determine tax liability in each jurisdiction, the right arm's length principle has to be applied. The OECD has issued Transfer Pricing Guidelines on this principle to avoid double taxation.
What's new
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25-Sep-2009
Two key objectives of the OECD work on the mutual agreement procedure (MAP) under tax treaties were to improve the timeliness of processing and completing MAP cases and to enhance the transparency of the MAP process. To those ends, the OECD has decided to make available to the public, via its website, annual statistics on the MAP caseloads of member countries and of non-OECD economies that agree to provide such statistics.
MAP statistics have now been provided for 2006 and 2007. Statistics for subsequent reporting periods will be posted on the OECD website as they become available.
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22-Sep-2009
On 21-22 September 2009, the OECD held a major conference “Transfer Pricing and Treaties in a Changing World”. Almost 700 transfer pricing and treaty experts from over 90 governments (OECD and non-OECD), the private sector, NGOs, academia and international organisations gathered in Paris for the event. In his opening address, Jeffrey Owens, Director of the OECD Centre for Tax Policy and Administration, stressed the significance of transfer pricing for OECD as well as non-OECD economies.
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from 09-Sep-2009 to 09-Jan-2010
On 9 September, the OECD released for public comment a proposed revision of Chapters I-III of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. This follows from the release in May 2006 of a discussion draft on comparability issues and in January 2008 of a discussion draft on transactional profit methods, and from discussions with commentators during a two-day consultation that was held in November 2008. Interested parties are invited to submit comments by 9 January 2010 to Jeffrey Owens, Director,CTPA (jeffrey.owens@oecd.org).
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09-Sep-2009
On 7 September 2009, the OECD released the 2009 edition of its Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. This edition incorporates an update of Chapter IV to reflect the latest developments in the area of dispute resolution as well as updates to the Foreword, Preface and Council Recommendation. It was released in time for the Conference Transfer Pricing and Treaties in a Changing World.
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from 09-Jun-2009 to 10-Jun-2009
On 9-10 June 2009, the OECD held a consultation with business commentators on its discussion draft on the transfer pricing aspects of business restructurings which was released for public comment in September 2008.
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06-Mar-2009
On 19 September 2008, the OECD Committee on Fiscal Affairs released for comment a discussion draft on the Transfer Pricing Aspects of Business Restructurings. The OECD has now published the comments received on that draft.
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26-Jan-2009
On 7 July 2008, the OECD Committee on Fiscal Affairs called for comments on a draft new Article 7 of the OECD Model Tax Convention and related Commentary changes. The OECD has now published the comments received on that draft.
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19-Nov-2008
On 17-18 November 2008, the OECD held a consultation with business commentators on comparability and profit methods for transfer pricing purposes. The consultation followed the release of two discussion drafts on comparability (May 2006) and transactional profit methods (January 2008) under the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, both of which attracted very detailed responses from the business community.
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19-Sep-2008
On 19 September 2008, the Committee on Fiscal Affairs released for public comment a discussion draft on the transfer pricing aspects of business restructurings. Comments should be sent before 19 February 2009 to Jeffrey Owens, Director, CTPA (jeffrey.owens@oecd.org).
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18-Jul-2008
On 17 July 2008, the OECD Council approved the release of the final Report on the Attribution of Profits to Permanent Establishments. An interim version of Parts I-III of the Report had previously been released in December 2006, and a discussion draft version of Part IV was released in August 2007. The Report was subsequently finalised and approved by the Committee on Fiscal Affairs on 24 June 2008.
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from 07-Jul-2008 to 31-Dec-2008
On 24 June 2008, the Committee on Fiscal Affairs approved the Report on Attribution of Profits to Permanent Establishments. It also approved the release, for public comment, of the second part of the implementation package for the conclusions of that Report, i.e. a new version of Article 7 and its Commentary. This new Article and related Commentary changes are now being released as a discussion draft for public comment. Comments should be sent before 31 December 2008 to Jeffrey Owens, Director, CTPA (jeffrey.owens@oecd.org).
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25-Jan-2008
More than 250 participants met in Mumbai, India, on 23-25 January 2008 to discuss a broad range of international tax issues at the Conference “At the Crossroads of Tax Co-operation: IFA (India) – OECD” that was jointly organized by the Indian Branch of the International Fiscal Association (IFA) and the Organisation for Economic Co-operation and Development (OECD) to mark the accession of India as observer to the OECD Committee on Fiscal Affairs.
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25-Jan-2008
The OECD is issuing an invitation to comment on a series of issues notes that was drafted by the Committee on Fiscal Affairs' Working Party No. 6, building on experience acquired by countries in applying transactional profit methods since the adoption of the Transfer Pricing Guidelines in 1995 and on comments received from the business community.
Comments may be submitted by 30 April 2008 to Jeffrey Owens, Director, CTPA (jeffrey.owens@oecd.org).
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The Taxation of Employee Stock Options
