Latest Documents


  • 27-January-2011

    English

    OECD releases a scoping document for its new project on the transfer pricing aspects of intangibles

    The OECD has now released a scoping document for its new project on the transfer pricing aspects of intangibles.

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  • 26-January-2011

    English, , 46kb

    The OECD has an extremely ambitious programme of work planned for 2011

    Article by Caroline Silberztein, Head of the Transfer Pricing Unit, OECD Centre for Tax Policy and Administration, published in the January 2011 issue of BNA Transfer Pricing International Journal.

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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.

  • 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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  • 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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  • 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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  • 2-July-2010

    English

    OECD invites comments on the scoping of its future project on the Transfer Pricing Aspects of Intangibles

    The OECD’s Committee on Fiscal Affairs is now completing its work on two transfer pricing projects which the OECD Council will be asked to approve by the end of July in the form of revisions to the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.

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  • 28-January-2010

    English, , 114kb

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