Handbook - Developing Partnerships with Non-OECD Economies - Section 2.6

2. EVALUATION AND IMPACT

2.6 Association with OECD Standards and Guidelines

In the 2005 update of the OECD Model Tax Convention, 25 NOEs stated their positions on the model as a direct result of CFA’s partnership activities with these NOEs.  The NOEs that have stated their positions on the Model Tax Convention are Albania, Argentina, Belarus, Brazil, Bulgaria, China, Croatia, Estonia, Gabon, Israel, Ivory Coast, Latvia, Lithuania, Malaysia, Morocco, Philippines, Romania, Russia, Serbia and Montenegro, Slovenia, South Africa, Thailand, Tunisia, Ukraine, Vietnam.
Based on the information collected by the Secretariat, 9 NOEs (Argentina, Ecuador, India, Lithuania, Malaysia, Slovenia, South Africa, Thailand and Venezuela) have now adopted transfer pricing legislation that are based on the OECD Transfer Pricing Guidelines.  A number of NOEs such as Belarus, Colombia, Croatia, Namibia, Peru and Vietnam are also working on implementation issues relating to the OECD Transfer Pricing Guidelines with a view to using it as a basis for their transfer pricing legislation.