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. Numberous contributions have now been received and will be carefully examined by Working Party No. 6 on the Taxation of Multinational Enterprises.
An invitation to comment on a series of draft Issues notes that was developed by the Committee on Fiscal Affairs Working Party No. 6, building on experience acquired by countries since the adoption of the Transfer Pricing Guidelines in 1995 and on comments received from the business community in response to an invitation to comment on comparability issues in 2003.
The OECD is now issuing an open invitation to contribute on a number of issues in relation to transactional profit methods. As part of its procedures for monitoring the implementation of the 1995 Transfer Pricing Guidelines (“the 1995 TP Guidelines”), Working Party No. 6 of the OECD Committee on Fiscal Affairs selected the area of application of transactional profits as one of two areas to be considered in priority.
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In July 2004, the OECD Committee on Fiscal Affairs released a progress report on its work on improving the resolution of cross-border tax disputes. The report, entitled “Improving the Process for Resolving International Tax Disputes ” included various proposals aimed at improving the way that tax treaty disputes are resolved through the mutual agreement procedure (“MAP”). A number of these proposals referred to future work to be
This working paper describes the structure of the health care system in Hungary, highlights outstanding weaknesses and considers ways to make financing more stable and sustainable.
This working paper describes the main characteristics and the developments of the French tax system and examines some of its economic distortions and complexities.
Further to the posting on 27 January 2005 the CFA has now released for public comment a discussion draft of the 4th and final part of its Report on the Attribution of Profits to a Permanent Establishment . Part I of the Report deals with general considerations, Part II deals with traditional banking, Part III deals with global trading and Part IV deals with insurance.
Since the early 1990s, when France's general government deficit reached a disturbing 6% of GDP, the country's public finances have progressed substantially, even though significantly further improvement is required. This paper examines the tools available to policy makers to meet this challenge.
Key indicators show Germany belonging to the countries in the OECD with strong innovation activity even though some weakening in Germany’s position relative to other OECD countries has occurred recently, as discussed in this working paper.
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A revised discussion draft of Part 1 (General) for public comments. Written comments should be submitted no later than 28 September 2004.