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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
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Comments received from BIAC (pdf, english)
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Comments received from E.C.S. (pdf, english)
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- Comments received from Grant Thornton (pdf, english)
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Comments received from IFA Korea (pdf, english)
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Comments received from INTECAP (pdf, english)
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