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Transfer pricing relates to the determination of the taxable profits that an enterprise realises from transactions with associated enterprises. The international consensus is that these profits should be comparable to the profits that would have been realised in comparable transactions between independent enterprises. This is the arm’s length principle, embodied in Article 9 of the OECD Model Tax Convention and in many countries' domestic legislation. The Transfer Pricing Guidelines provide guidance on its application.
What's new
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19-Jan-2012
The 7th meeting of the Forum on Tax Administration, which brought together the heads of tax administrations from 43 countries, concluded with a unified and strengthened commitment to combat offshore tax abuse.
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11-Jan-2012
Ms. Marlies de Ruiter has been appointed Head of the Tax Treaty, Transfer Pricing and Financial Transactions Division of the OECD's Center for Tax Policy and Administration to replace Mary Bennett. She will take up her duties on 1 February 2012.
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08-Dec-2011
The OECD has released statistics on the mutual agreement procedure (MAP) caseloads of OECD member countries and certain non-OECD economies for the 2010 reporting period. These statistics reveal a slight decrease in the total number of open MAP cases reported by OECD member countries as compared to the 2009 reporting period. The collection of these statistics forms part of the OECD's continuing work to improve the timeliness of processing and completing MAP cases under tax treaties and to enhance the transparency of the MAP process.
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16-Nov-2011
On 7-9 November 2011, Working Party No. 6’s Special Session on the Transfer Pricing Aspects of Intangibles met with private sector representatives to discuss definitional and ownership issues related to intangibles. The agenda for the meeting, presentation material submitted by private sector participants and list of participants have now been published.
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29-Aug-2011
The OECD’s Centre for Tax Policy and Administration (CTPA) is pleased to announce that Mr. Joseph Andrus has been appointed Head of the Transfer Pricing Unit within the CTPA’s Tax Treaty, Transfer Pricing and Financial Transactions Division. He will take up his position on 1st October 2011 following the departure of Ms. Caroline Silberztein.
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08-Jul-2011
Following two recent invitations for public comment on the administrative aspects of transfer pricing, the OECD has now published the comments received which will be used to inform the OECD’s work in this area, including the review of the existing guidance on safe harbours in Chapter IV of the Transfer Pricing Guidelines.
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10-Jun-2011
As part of its project on the administrative aspects of transfer pricing, the OECD identified and analysed transfer pricing simplification measures implemented by 33 OECD and non-OECD economies. The key findings from this analysis and the country responses have now been published.
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17-May-2011
OECD Secretary-General, Angel Gurría, welcomed the recent proposal of new draft transfer pricing legislation by the Russian Federation’s Ministry of Finance.
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29-Mar-2011
On 21-23 March 2011, Working Party No. 6’s Special Session on the Transfer Pricing Aspects of Intangibles met with private sector representatives to discuss the valuation of intangibles for transfer pricing purposes. The agenda for the meeting, presentation material submitted by private sector participants and list of participants have now been published.
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27-Jan-2011
Following an intensive consultation process in 2010, the OECD has now released a scoping document for its new project on the transfer pricing aspects of intangibles which was approved by the Committee on Fiscal Affairs on 25 January 2011.
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26-Nov-2010
As part of its ongoing work to improve the timeliness of processing and completing mutual agreement procedure (MAP) cases under tax treaties and to enhance the transparency of the MAP process, the OECD has made available statistics on MAP caseloads for OECD member countries and certain non-OECD economies for the 2008 and 2009 reporting periods. The statistics for these reporting periods now divide MAP cases into cases with OECD member countries and cases with non-OECD economies for countries that have provided that information.
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10-Nov-2010
On 9 November 2010, Working Party No. 6 met with commentators from the private sector to discuss the scoping of its new project on the Transfer Pricing Aspects of Intangibles. The agenda for the day has now been published.
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23-Sep-2010
On 2 July 2010, the OECD Committee on Fiscal Affairs released an invitation to comment on the scoping of a future project on the Transfer Pricing Aspects of Intangibles, to be carried out by Working Party No. 6 on the Taxation of Multinational Enterprises. The OECD has now published the comments received. These comments will be discussed by the Working Party at its November 2010 meeting.
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22-Jul-2010
The OECD Council has today approved the 2010 version of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. Chapters I-III were substantially revised, with new guidance on the selection and application of transfer pricing methods and on comparability analysis. A new Chapter IX on the transfer pricing aspects of business restructurings was added.
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22-Jul-2010
The OECD Council has today approved the 2010 Update to the Model Tax Convention. The contents of the update were previously released in draft form on 21 May and, after some final changes, were approved by the Committee on Fiscal Affairs on 22 June before being presented to the Council for final approval. A revised version of the condensed version of the OECD Model that will include the changes resulting from the update will be published in September.
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02-Jul-2010
from 2-Jul-2010 to 15-Sept-2010
The OECD is considering starting a new project on the Transfer Pricing Aspects of Intangibles and is inviting comments from interested parties on the scoping of such a project. Comments should be sent before 15 September 2010 to Jeffrey Owens, Director, CTPA (jeffrey.owens@oecd.org).
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28-Jan-2010
On 27 January, tax and development experts decided to set up an Informal Task Force on Tax and Development. With developing countries and other key stakeholders – including NGOs and business – as members, the Task Force will develop clear and effective mechanisms to make progress in the field of tax and development. With a mapping out of existing international efforts as its first assignment, participants agreed on a general set of principles to guide followup action and recognized the importance of working together and with other relevant international institutions. See the full Statement.
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