Publications


  • 16-August-2010

    English

    OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2010

    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.

  • 30-July-2010

    English

    Sickness, Disability and Work: Breaking the Barriers: Canada - Opportunities for Collaboration

    Sickness and disability policy reform has been a priority for OECD countries wanting to improve employment and social outcomes in this domain. The recent recession and corresponding fall in labour demand is expected to hit marginalised workers, including workers with health problems or disability, harder than the broader working-age population. There is a pressing need for policy makers to address the recent “medicalisation” of labour market problems, a phenomenon that appears to underlie much of the difficulties countries find in disability policy making. This report is an assessment of the Canadian situation, albeit through the lens of the federal government and the provinces of Québec, British Columbia and Manitoba. It looks at the current state of play following a decade of various reforms and preceding a period where further revisions are likely.
  • 30-July-2010

    English

    Energy Technology Initiatives - Implementation through Multilateral Co-operation

    Through its broad range of multilateral technology initiatives (Implementing Agreements), the IEA enables member and non-member countries, businesses, industries, international organisations and non-government organisations to share research on breakthrough technologies, to fill existing research gaps, to build pilot plants and to carry out deployment or demonstration programmes.

    Energy Technology Initiatives: Implementation through Multilateral Co-operation, highlights the most significant recent achievements of the 42 IEA Implementing Agreements.
  • 26-July-2010

    English

    International Nuclear Law - History, Evolution and Outlook

    This publication commemorates the International School of Nuclear Law which is celebrating its 10th anniversary in 2010. The purpose of the publication is to provide an overview of the international nuclear law instruments, their background, content and development over the years and to present an outlook on future needs in the field of international nuclear law. Renowned experts in the nuclear law field have contributed scholarly papers on the various aspects of international nuclear law, including international institutions, protection against ionising radiation, nuclear safety, non-proliferation of nuclear weapons and safeguards, nuclear security, transport of nuclear material and fuel, management of spent fuel and radioactive waste, liability, compensation and insurance for nuclear damages, environmental protection and international trade in nuclear material and equipment. This publication is dedicated to the school’s 500+ alumni from all around the world.

  • 23-July-2010

    English

    Test No. 439: In Vitro Skin Irritation - Reconstructed Human Epidermis Test Method

    This Test Guideline describes an in vitro procedure that may be used for the hazard identification of irritant chemicals (substances and mixtures) in accordance with the UN Globally Harmonized System of Classification and Labelling (GHS) Category 2.  It is based on reconstructed human epidermis (RhE), which in its overall design closely mimics the biochemical and physiological properties of the upper parts of the human skin. Cell viability is measured by enzymatic conversion of the vital dye MTT into a blue formazan salt that is quantitatively measured after extraction from tissues. Irritant test substances are identified by their ability to decrease cell viability below defined threshold levels (below or equal to 50% for UN GHS Category 2). This Test Guideline also includes a set of Performance Standards for the assessment of similar and modified RhE-based test methods. There are three validated test methods that adhere to this Test Guideline. Depending on the regulatory framework and the classification system in use, this procedure may be used to determine the skin irritancy of test substances as a stand-alone replacement test for in vivo skin irritation testing, or as a partial replacement test, within a tiered testing strategy.

  • 23-July-2010

    English

    Test No. 442B: Skin Sensitization - Local Lymph Node Assay: BrdU-ELISA

    The Local Lymph Node Assay: BrdU-ELISA (LLNA:BrdU-ELISA) is a non-radioactive modification to the LLNA method for identifying potential skin sensitizing test substances and measuring the proliferation of lymphocytes they induce in the auricular lymph nodes. The method described in mouse (CBA/JN strain) is based on the use of measuring 5-bromo-2-deoxyuridine (BrdU) content, an analogue of thymidine, as an indicator of this proliferation. A minimum of four animals is used per dose group, with a minimum of three concentrations of the test substance, plus a concurrent negative control group and a positive control group. The experimental schedule is during 6 days. Thereafter, the animals are killed and a single cell suspension of lymph node cells (LNC) is prepared. The procedure for preparing the LNC is crucial, in particular for the small lymph nodes in NC animals. Then the BrdU content in DNA of lymphocytes is measured by ELISA using a commercial kit. This study includes: measurements (weighing, BrdU) and clinical daily observations. The results are expressed as the Stimulation Index (SI) obtained by calculation from the mean BrdU labelling index. The SI should be ¡Ý1.6 before further evaluation of the test material as a potential skin sensitizer is warranted.

  • 23-July-2010

    English

    Test No. 233: Sediment-Water Chironomid Life-Cycle Toxicity Test Using Spiked Water or Spiked Sediment

    This Guideline is designed to assess the effects of prolonged exposure of chemicals to the life-cycle of the sediment-dwelling freshwater dipteran Chironomus sp. First instar chironomid larvae are exposed to five concentrations of the test chemical in sediment-water systems. The test substance is spiked into the water or alternatively the sediment, and first instar larvae are subsequently introduced into test beakers in which the sediment and water concentrations have been stabilised. Chironomid emergence, time to emergence, and sex ratio of the fully emerged and alive midges are assessed. Emerged adults are transferred to breeding cages, to facilitate swarming, mating and oviposition. The number of egg ropes produced and their fertility are assessed. From these egg ropes, first instar larvae of the 2nd generation are obtained. These larvae are placed into freshly prepared test beakers (spiking procedure as for the 1st generation) to determine the viability of the 2nd generation through an assessment of their emergence, time to emergence and the sex ratio of the fully emerged and alive midges. All data are analysed either by a regression model to estimate the concentration that would cause X% reduction in the relevant endpoint, or by using hypothesis testing to determine a No Observed Effect Concentration (NOEC).

  • 23-July-2010

    English

    Test No. 417: Toxicokinetics

    This Test Guideline describes in vivo studies that provide information on mass balance, absorption, bioavailability, tissue distribution, metabolism, excretion, and basic toxicokinetic parameters [e.g. AUC], as well as supplemental approaches that may provide useful information on toxicokinetics. Information from toxicokinetic studies helps to relate concentration or dose to the observed toxicity and to understand its mechanism of toxicity. The test substance ("unlabelled" or "radiolabelled" forms) is normally administered by an oral route, but other routes of administration may be applicable. Single dose administration of the substance (preferably a minimum of two dose levels) may be adequate, but repeated dose may be needed in some circumstances. Toxicokinetic studies should preferably be carried out in the same species as that used in other toxicological studies performed with the substance (normally the rat, a minimum of 4 animals of one sex for each dose). Initial estimation of absorption can be achieved by mass balance determination, but further investigations such as intravenous (IV) administration and biliary excretion studies might be necessary. Bioavailability can be determined from plasma/blood kinetics of oral and IV groups. The percent of the total dose in tissues should at a minimum be measured at the termination of experiment,but additional time points may also be needed. Metabolites present at 5 % or greater of the administered dose should be identified. The rate and extent of excretion of the administered dose should be determined by measuring the percent recovered dose from urine, faeces and expired air.

  • 23-July-2010

    English

    Test No. 487: In Vitro Mammalian Cell Micronucleus Test

    The in vitro micronucleus test is a genotoxicity test for the detection of micronuclei in the cytoplasm of interphase cells. Micronuclei may originate from acentric chromosome fragments (i.e. lacking a centromere), or whole chromosomes that are unable to migrate to the poles during the anaphase stage of cell division. The assay detects the activity of clastogenic and aneugenic test substances in cells that have undergone cell division during or after exposure to the test substance. This Test Guideline allows the use of protocols with and without the actin polymerisation inhibitor cytochalasin B. Cytochalasin B allows for the identification and selective analysis of micronucleus frequency in cells that have completed one mitosis, because such cells are binucleate. This Test Guideline also allows the use of protocols without cytokinesis block provided there is evidence that the cell population analysed has undergone mitosis.

  • 23-July-2010

    English

    Test No. 317: Bioaccumulation in Terrestrial Oligochaetes

    This Test Guideline describes procedures designed to assess bioaccumulation of chemicals in soil oligochaetes. The parameters which characterise the bioaccumulation of a substance include the bioaccumulation factor (BAF), the uptake rate constant (ks) and the elimination rate constant (ke). The test consists of two phases: the uptake (exposure) phase and the elimination (post-exposure) phase. An elimination phase is always required unless uptake of the test substance during the exposure phase has been insignificant. The test organisms are exposed to the test substance during the uptake phase. The test substance is incorporated into the soil; it is recommended to use the artificial soil described in the OECD Test Guideline 207 (Earthworm, acute toxicity test). The uptake phase should be of 14 days (enchytraeids) or 21 days (earthworms) unless it is demonstrated that steady state has been reached. For the elimination phase, the worms are transferred to a soil free of test substance. The elimination phase is generally of 21 days.

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