Tax

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017

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Published on July 10, 2017

Also available in: French

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This 2017 edition of the OECD Transfer Pricing Guidelines incorporates the substantial revisions made in 2016 to reflect the clarifications and revisions agreed in the 2015 BEPS Reports on Actions 8-10 Aligning Transfer pricing Outcomes with Value Creation and on Action 13 Transfer Pricing Documentation and Country-by-Country Reporting. It also includes the revised guidance on safe harbours approved in 2013 which recognises that properly designed safe harbours can help to relieve some compliance burdens and provide taxpayers with greater certainty. Finally, this edition also contains consistency changes that were made to the rest of the OECD Transfer Pricing Guidelines.  The OECD Transfer Pricing Guidelines were approved by the OECD Council in their original version in 1995.

TABLE OF CONTENTS

Foreword
Preface
The Arm's Length Principle
Transfer Pricing Methods
Comparability Analysis
Administrative Approaches to Avoiding and Resolving Transfer Pricing Disputes
Documentation
Special Considerations for Intangibles
Special Considerations for Intra-Group Services
Cost Contribution Arrangements
Transfer Pricing Aspects of Business Restructurings
Appendix. Recommendation of the Council on the Determination of Transfer Pricing between Associated Enterprises [C(95)126/Final, as amended
Annexes13 chapters available
Annex to the OECD Transfer Pricing Guidelines
Annex I to Chapter II. Sensitivity of Gross and Net Profit Indicators
Annex II to Chapter II. Example to Illustrate the Application of the Residual Profit Split Method
Annex III to Chapter II. lllustration of Different Measures of Profits When Applying a Transactional Profit Split Method
Annex to Chapter III. Example of a Working Capital Adjustment
Annex I to Chapter IV. Sample Memoranda of Understanding for Competent Authorities to Establish Bilateral Safe Harbours
Annex II to Chapter IV. Guidelines for Conducting Advance Pricing Arrangements under the Mutual Agreement Procedure (MAP APAs)
Annex I to Chapter V. Transfer Pricing Documentation – Master file
Annex II to Chapter V. Transfer Pricing Documentation – Local file
Annex III to Chapter V. Transfer Pricing Documentation – Country-by-Country Report
Annex IV to Chapter V. Country-by-Country Reporting Implementation Package
Annex to Chapter VI. Examples to Illustrate the Guidance on Intangibles
Annex to Chapter VIII. Examples to Illustrate the Guidance on Cost Contribution Arrangements
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