Transfer Pricing

News & Events

News

Attribution of profits to permanent establishments of insurance companies and current status of the project

30-Sep-2005

On 27 June 2005 the OECD Committee on Fiscal Affairs released for public comment a Discussion Draft on the Attribution of Profits to Permanent Establishments of Insurance Companies.  The contributions that have been received to date are now available.

Available for public comment: Discussion Draft of the Report on the Attribution of Profits to a Permanent Establishment - Part IV (Insurance)

27-Jun-2005

The OECD Committee of Fiscal Affairs has just released for public comment a Discussion Draft of the Report on the attribution of Profits to a Permanent Establishment - Part IV (Insurance). Parts I-III of the Report have already been the subject of extensive consultation but this is the first time that Part IV has been exposed to the public. The deadline for comment is 16 September 2005. Depending on the nature of comments received a decision will be taken on whether it would be useful to have a face to face meeting with commentators.

OECD engages dialogue on business restructuring: 2nd CTPA Roundtable focused on business restructuring

04-Mar-2005

The OECD Centre for Tax Policy and Administration held its 2nd CTPA Roundtable in Paris on 26-27 January 2005, on the theme “Business Restructuring”. The Roundtable was attended by senior officials from OECD member countries as well as from China, South Africa and Singapore and by a wide panel of private sector representatives. The discussion covered treaty, transfer pricing and indirect taxes issues involved in business restructurings.

Finalising the work on the attribution of profits to a PE

27-Jan-2005

Further to the posting of 19 November, the CFA (at its meeting on 25-26 January)has reviewed the process for finalising the work on the attribution of profits to a PE.

US business engages OECD on international tax issues

18-Jan-2005

Information note on the International Tax Conference, organised in Washington on 13-14 January 2005.

OECD's Review of Mexico's Transfer Pricing systems gives positive evaluation

07-Jan-2005

An OECD peer review of Mexico's transfer pricing legislation and practices has concluded with an overall positive appraisal of the systems in place and the observation that many lessons learned in Mexico may be relevant for other economies with similar economic structures.  Detailed report now available on line.

Attribution of Profits to a Permanent Establishment: revised timetable for completion

19-Nov-2004

In the light of the latest business comments, WP 6 will propose to the CFA that the process for taking this work forward be reviewed. It already seems clear, however, that the final versions of Parts I-III will NOT be released in January 2005 as originally intended.  A final decision on these proposals will be made when the CFA meets at the end of January 2005. 

Attribution of Profits to a Permanent Establishment: Revised discussion draft for public comment

03-Aug-2004

OECD releases a revised discussion draft of Part I (General) for public comment and provides progress report on Parts II-IV. Written comments should be submitted no later than 28 September 2004.

Transfer Pricing Experts Meeting

17-Jun-2004

Agenda and List of Participants for the second of a series of meetings with Transfer Pricing Experts, which was held on 24 May 2004.




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

Transfer Pricing Guidelines

Report on the Attribution of Profits to Permanent Establishments Parts I (General Considerations) , II (Banks) and III (Global Trading)

Report on the Attribution of Profits to Permanent Establishments, Parts I-III

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

The Taxation of Employee Stock Options