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This paper provides data and interpretation on the fiscal resources of sub-central government in OECD countries. It presents a set of fiscal autonomy indicators such as revenue and expenditure decentralisation, tax autonomy, intergovernmental grants and the stringency of fiscal rules.
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.
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...