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In the transfer pricing context, business restructurings are defined as the cross-border redeployment by a multinational enterprise (“MNE”) of its functions, assets and/or risks. Business restructurings can have a dramatic impact on the allocation of a multinational enterprise’s taxable profits among the countries in which it operates. The Council of the OECD approved on 22 July 2010 a new Chapter IX of the Transfer Pricing Guidelines, which provides detailed guidance on the transfer pricing aspects of business restructurings.
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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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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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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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