Transfer Pricing: The OECD launches an invitation to comment on comparability issues

As part of its procedures for monitoring the implementation of the 1995 Transfer Pricing Guidelines ("the 1995 TP Guidelines"), the Working Party No. 6 of the OECD Committee on Fiscal Affairs has selected two areas to be considered in priority.

  • The application of transactional profit methods (i.e. the transactional profit split methods and the transactional net margin method) and
  • Comparability issues encountered when applying the transfer pricing methods authorised by the 1995 TP Guidelines (whether traditional transaction methods or transactional profit methods).

 

As a first step, we are issuing an open invitation to comment on comparability issues. An invitation to comment on issues related to profit methods will be issued later.

 

Word Version: English / French
PDF Version: English / French

 

Comments Received

Top of page

Bookshop

The OECD's Guidelines on dealing with commercial transactions between different parts of a multinational group.

Transfer Pricing Guidelines

Final Report on the Attribution of Profits to Permanent Establishments.

Report on the Attribution of Profits to Permanent Establishments

OECD Tax Policy Studies No. 11: The Taxation of Employee Stock Options

The Taxation of Employee Stock Options