Transfer Pricing

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News

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.

Memorandum of understanding signed at the OECD-Vienna Multilateral Tax Centre

11-Mar-2004

Ambassador Ulrich Stacher of Austria and Mr Jeffrey Owens, Director of the Centre for Tax Policy and Administration, signed a memorandum of understanding on the implementation of the multilateral tax programme at the OECD-Vienna Multilateral Tax Centre. 

Transfer Pricing Experts Meeting

The OECD Secretariat has held on 21st November 2003 the first of a series of meetings with a group of transfer pricing experts having a variety of professional backgrounds and coming from a variety of OECD countries.

Discussion Draft on Tax Treaty Issues Related to Cross-Border Pensions

Ageing populations in OECD countries, the increasing mobility of workers and, more generally, the globalisation of the economy have increased the importance of the tax issues arising from situations where cross-border pension contributions or benefits are paid. Tax treaties have an important role to play in solving such issues. Working Party No. 1, the subsidiary body of the OECD Committee on Fiscal Affairs that deals with tax treaty issues, has prepared a public discussion draft that seeks to provide more guidance on the tax problems related to cross-border pension arrangements, contributions and benefits. Comments on this draft should be sent to the OECD before 15 January 2004.

Dispute Resolution: a public consultation on 17 December 2003

The OECD has launched a project to improve the dispute resolution mechanisms for corss border tax disputes.  An invitation for the public consultation between business representatives, senior government officials and the OECD Secretariat will be sent to persons who have responded to the questionnaire  by 7 November 2003.  The concultation will be held in Paris, France on 17 December 2003

Attribution of Profits to a Permanent Establishment: Revised Part II & III of the Discussion Draft

15-Oct-2003

OECD publishes comments received on the discussion draft regarding the attriubtion of profits to a permanent establishment.  Results from these comments will be published in April/May 2004.




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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