Publications & Documents


  • 16-August-2010

    English

    Public comments received on the discussion draft on the application of Article 17 (Artistes and Sportsmen) of the OECD Model Tax Convention

    The OECD has published the comments received on a proposed draft of the new Article 17 of the OECD Model Tax Convention (Artistes and Sportsmen).

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  • 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.

  • 10-August-2010

    English, , 18kb

    A Progress Report on the Jurisdictions Surveyed by the OECD Global Forum (2 April 2009)

    The internationally agreed standard, developed by OECD and non-OECD countries in the context of the OECD’s Global Forum on Taxation and endorsed by G20 Finance Ministers in 2004 and by the UN Committee of Experts on International Co-operation in Tax Matters in October 2008, requires exchange of information on request in all tax matters for the administration and enforcement of domestic tax law without regard to a domestic tax interest

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  • 3-August-2010

    English, , 910kb

    Transfer Pricing Methods (July 2010)

    This document is part of a series of transfer pricing explanatory notes that were drafted by the Secretariat and which are intended to provide a first approach to some of the key topics covered in the Transfer Pricing Guidelines.

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  • 3-August-2010

    English, , 510kb

    Comparability (July 2010)

    This document is part of a series of transfer pricing explanatory notes that were drafted by the Secretariat and which are intended to provide a first approach to some of the key topics covered in the Transfer Pricing Guidelines.

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  • 3-August-2010

    English, , 412kb

    Comparability adjustments (July 2010)

    This document is part of a series of transfer pricing explanatory notes that were drafted by the Secretariat and which are intended to provide a first approach to some of the key topics covered in the Transfer Pricing Guidelines.

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  • 30-July-2010

    English

    Korea: Health-care reform

    Korea’s health-care system has contributed to the marked improvement in health conditions, while limiting spending to one of the lowest levels in the OECD through high patient co-payments and limited coverage of public health insurance.

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  • 29-July-2010

    English, , 520kb

    Arm's Length Range (July 2010)

    This document is part of a series of transfer pricing explanatory notes that were drafted by the Secretariat and which are intended to provide a first approach to some of the key topics covered in the Transfer Pricing Guidelines.

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  • 28-July-2010

    English, , 193kb

    Location Savings (July 2010)

    This document is part of a series of transfer pricing explanatory notes that were drafted by the Secretariat and which are intended to provide a first approach to some of the key topics covered in the Transfer Pricing Guidelines.

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  • 28-July-2010

    English

    Implementing the Tax Transparency Standards: A Handbook for Assessors and Jurisdictions

    This handbook is intended to assist the assessment teams and the reviewed jurisdictions that are participating in the Global Forum on Transparency and Exchange of Information (the “Global Forum”) peer reviews and non-member reviews.

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