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This page provides links to available material relating to the different sessions of the Conference.
General information on OECD and the Centre for Tax Policy and Administration
Model Tax Convention on Income and on Capital (2008)
Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (1995)
Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (2009)
International Tax Dialogue
Plenary Session: Adjustments and Corresponding Adjustments – The Role of Articles 7, 9 and 25 of the Model Tax Convention
Model Tax Convention on Income and on Capital – Articles 7 (Business Profits), 9 (Associated Enterprises) and 25 (Mutual Agreement Procedure), Including Commentary (2008)
Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations – Chapter IV on Administrative Approaches to Avoiding and Resolving Transfer Pricing Disputes (1995).
Report on the Attribution of Profits to Permanent Establishments (2008)
Discussion Draft on a New Article 7 (Business Profits) of the OECD MTC (2008)
Discussion Draft on a New Art. 7 of the OECD Model Convention – article by Mary Bennett & Raffaele Russo, IBFD (2009)
Klaus Vogel Lecture – Tax Treaties and Schrödinger’s Cat – Jacques Sasseville, IBFD (2009)
Report on Transfer Pricing, Corresponding Adjustments and the Mutual Agreement Procedure (1982)
Manual on Effective Mutual Agreement Procedures (MEMAP - 2007)
Report on Improving the Resolution of Tax Treaty Disputes (2007)
Internet Page on Dispute Prevention and Resolution
Internet Page on Tax treaties: www.oecd.org/ctp/tt
Internet Page on Transfer Pricing: www.oecd.org/ctp/tp
Parallel Session 1A: Information Powers and Transfer Pricing
Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations – Chapter IV on Administrative Approaches to Avoiding and Resolving Transfer Pricing Disputes (1995)
Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations – Chapter V on Documentation (1995)
Model Tax Convention on Income and on Capital – Article 26 on Exchange of Information, including Commentary (2008)
Manual on Information Exchange (2006)
Internet Page on Exchange of Information: www.oecd.org/ctp/eoi
Parallel Session 1B: Deductibility of Interest in Related Party Situations
Model Tax Convention on Income and on Capital – Article 11 on Interest, including Commentary (2008)
Model Tax Convention on Income and on Capital – Article 24 on Nondiscrimination, including Commentary (2008)
Report on Thin Capitalisation (1986)
Parallel Session 2A: Transfer Pricing in a Downturn Economy
Discussion Draft on the Transfer Pricing Aspects of Business Restructurings (2008)
Internet Page on Business Restructurings: www.oecd.org/ctp/tp/br
Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations – Chapter I on the Arm’s Length Principle (1995)
Parallel Session 2B: Attribution of Profits to Permanent Establishments
Report on the Attribution of Profits to Permanent Establishments (2008)
Model Tax Convention on Income and on Capital – Article 7 (Business Profits), including Commentary (2008)
Discussion Draft on a New Article 7 (Business Profits) of the OECD MTC (2008)
Discussion Draft on a New Article 7 of the OECD Model Convention – Article by Mary Bennett & Raffaele Russo, IBFD (2009)
Internet Page on Profits of Permanent Establishments: www.oecd.org/ctp/tp/pe
Parallel Session 3A: Transfer Pricing and Customs
Press Statement of the WCO/OECD International Conference on Transfer Pricing and Customs Valuation, Brussels (2007)
Summary Remarks of WCO Secretary General at the WCO/OECD International Conference on Transfer Pricing and Customs Valuation, Brussels (2007)
Transfer Pricing, Customs Duties and VAT Rules: Can We Bridge the Gap? – article by L. Ping & C. Silberztein, World Commerce Review (2007)
Section 1059A: An Obstacle to Achieving Consistent Legislation? – Article by Mayra Lucas, IBFD (2008)
Parallel Session 3B: Treaty and Transfer Pricing Aspects of Intangibles Characterization
Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations – Chapter VI on Special Considerations for Intangible Property (1996)
Model Tax Convention on Income and on Capital – Article 12 (Royalties), including Commentary (2008)
Plenary Session: Recent Developments in the Areas of Transfer Pricing and Treaties
Other relevant documents
Discussion draft on comparability (2006)
Discussion draft on profit methods (2008)
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