Transfer pricing

Comparability: the OECD invites comment on a series of draft Issues notes


10 May 2006

As part of its procedures for monitoring the implementation of the 1995 Transfer Pricing Guidelines, Working Party No. 6 of the OECD Committee on Fiscal Affairs selected two areas to be considered in priority:

  • Comparability issues encountered when applying the transfer pricing methods authorised by the 1995 TP Guidelines and
  • The application of transactional profit methods (i.e., the transactional profit split methods and the transactional net margin method).

While recognising that the two projects are intrinsically linked, the Working Party started with a review of comparability issues in general. An open invitation to comment on comparability issues was released in 2003. Detailed contributions were received from the business community, most of which are available on the OECD Internet site. Comments are now invited on the attached series of draft Issues notes that was developed by 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 the 2003 invitation.

A separate invitation to comment on issues related to profit methods was released on 27 February 2006.

Comments should be sent by 30 November 2006, preferably by e-mail, to Jeffrey Owens, Director of the OECD Centre for Tax Policy and Administration ( and copied to Caroline Silberztein, Head of the Transfer Pricing Unit, (


Comparability: the OECD invites comment on a series of draft Issues notes




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