Transfer Pricing

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News

Transactional Profit Methods: Responses to the OECD Invitation to Comment

18-Sep-2006

On 27 February 2006 the OECD released an open invitation to comment on a number of issues in relation to transactional profit methods described in the OECD's Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.  Numerous contributions have now been received and will be carefully examined by Working Party No. 6 on the Taxation of Multinational Enterprises.

Attribution of Profits to Permanent Establishments – Current Status of the Project

28-Jun-2006

The Committee on Fiscal Affairs has completed a review of the progress on the project on the attribution of profits to permanent establishments.   It has agreed on next steps for publishing new versions of Parts I - IV of the report and a draft implementation package of proposed changes to the articles and the commentary of the Model Tax Convention.

Consultation with Business on the Attribution of Profits to Permanent Establishments

25-Jan-2006

The OECD’s Centre for Tax Policy and Administration (CTPA) is organising a consultation with business on Part IV (Insurance) of the Discussion Draft on the Attribution of Profits to Permanent Establishments.  That meeting will take place on Friday, 31 March 2006, in Paris at the OECD offices.

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.




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Guidance on applying the arm’s length principle between different parts of a multinational group.

Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations

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

The Taxation of Employee Stock Options