The OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations provide guidance on the application of the “arm’s length principle”, which is the international consensus on transfer pricing, i.e. on the valuation, for tax purposes, of cross-border transactions between associated enterprises. In a global economy where multinational enterprises (MNEs) play a prominent role, transfer pricing is high on the agenda of tax administrators and taxpayers alike. Governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdictions and that the tax base reported by MNEs in their respective countries reflect the economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation that may result from a dispute between two countries on the determination of an arm’s length remuneration for their cross-border transactions with associated enterprises.
After having been originally published in 1979, the OECD Transfer Pricing Guidelines were approved by the OECD Council in their original version in 1995. A limited update was made in 2009, primarily to reflect the adoption, in the 2008 update of the Model Tax Convention, of a new paragraph 5 of Article 25 dealing with arbitration, and of changes to the Commentary on Article 25 on mutual agreement procedures to resolve cross-border tax disputes. In the 2010 edition, Chapters I-III were substantially revised, with new guidance on: the selection of the most appropriate transfer pricing method to the circumstances of the case; the practical application of transactional profit methods (transactional net margin method and profit split method); and on the performance of comparability analyses. Furthermore, a new Chapter IX, on the transfer pricing aspects of business restructurings, was added. Consistency changes were made to the rest of the Guidelines.
Read about OECD efforts to help governments improve the domestic and global policies that affect business and markets in the wake of the global economic crisis.
The rapid growth of entrepreneurship and small firms has been one of the greatest successes in post-Communist transformation in Poland. SMEs have greatly contributed to employment, investment and value added in the Polish economy. However, key barriers to further growth remain in the business environment for SMEs and entrepreneurs. This book sets out the current SME and entrepreneurship climate, reviews SME and entrepreneurship issues and policies at national and local levels, and provides observations and recommendations for improving and supporting entrepreneurship and SMEs in Poland.
The markets for goods and services have undergone significant changes over the past 20 years. Regulatory reform, global markets, new technologies and growth in the role of services in economic activity have driven the changes which, in many instances, have provided significant benefits to consumers. Relatively little attention has been paid to the challenges these developments have posed for consumers. More choice and more complexity in many markets have made it increasingly difficult for them to compare and assess the value of products and services. The challenges for consumers have raised similar challenges for the government authorities responsible for protecting them from unfair commercial practices and fraud.
This book examines how markets have evolved and provides insights for improved consumer policy making. It explores, for the first time, how what we have learned through the study of behavioural economics is changing the way policy makers are addressing problems.
English, , 942kb
G20 Leaders have committed to forego protectionism and have requested public reports on their adherence to this commitment. The third report by OECD and UNCTAD on investment and investment-related measures covers the period from November 2009 to May 2010.
English, , 2,417kb
G20 Leaders have committed to forego protectionism and have requested public reports on their adherence to this commitment. This third joint report by OECD, UNCTAD and WTO on G20 trade and investment measures covers the period from 1 November 2009 until mid-May 2010.
The 2009 edition of the annual report focuses on consumer empowerment and responsible business conduct as well as providing an account of the actions adhering governments have taken over the 12 months to June 2009.
Small firms are playing an ever-increasing role in innovation, driven by changes in technologies and markets. Some spin-offs and high growth firms are having remarkable success. However, the broad bulk of small firms are not capitalising on their advantages. This book explores how government policy can boost innovation by improving the environment for entrepreneurship and small firm development and increasing the innovative capacities of enterprises. Policy findings and recommendations are presented in three key areas: embedding firms in knowledge flows; developing entrepreneurship skills; and social entrepreneurship. In addition, country notes present statistics and policy data on SMEs, entrepreneurship and innovation for 40 economies, including OECD countries, Brazil, China, Estonia, Indonesia, Israel, the Russian Federation, Slovenia and South Africa.
SMEs, Entrepreneurship and Innovation is part of the OECD Innovation Strategy, a comprehensive policy strategy to harness innovation for stronger and more sustainable growth and development, and to address the key global challenges of the 21st century. For more information about the OECD Innovation Strategy, see www.oecd.org/innovation/strategy.
English, , 441kb
This report presents the results of a fact finding survey on how governments seek to establish the identity of foreign investors, with a particular focus on transsectoral, security-related investment reviews. It was prepared for the OECD Freedom of Investment Roundtable to facilitate discussion of the issues by Roundtable participants.
English, , 323kb
Cross-border investment in agricultural production and farmland is not a new phenomenon, but it is growing in importance. This report reviews international initiatives for promoting responsible investment in agriculture and explores what contribution, if any, OECD investment instruments could make to these initiatives. This paper was commissioned for the OECD Freedom of Investment Roundtable to facilitate discussion of the issues by