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.
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.
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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.
OECD releases a revised discussion draft of Part I (General) for public comment on 3 August 2004 and provides progress report on Parts II-IV. Written comments should be submitted no later than 28 September 2004.
The OECD has launched a major project to improve the effectiveness of the Mutual Agreement Procedure (MAP) of Article 25 of the OECD Model Tax Convention.
As part of its procedures for monitoring the implementation of the 1995 Transfer Pricing Guidelines, the Working Party No. 6 of the OECD Committee on Fiscal Affairs has selected two areas to be considered in priority.
The 2003 Discussion Drafts address one of the most complex areas in international taxation, i.e. how to determine the taxing rights of a country where an enterprise that is resident of another country undertakes business through a permanent estab...
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Part III is dedicated to the global trading of financial instruments. The starting point for this analysis is naturally the 1998 OECD document "The taxation of Global Trading of Financial Instruments", which has been updated to take into consider...
The public comments which were received on Part I (General Considerations ) and Part II (Banks) of the 2001 discussion draft on the Attribution of Profits to Permanent Establishments.
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There is a considerable variation in the domestic laws of OECD Member countries regarding the taxation of Permanent Establishment. There is no consensus amongst the OECD Member countries with regards the interpretation of Article 7 of the OECD M...