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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.
New communication technologies and the worldwide spread of the Internet have prompted the appearance of new business models and have changed the ways in which almost any business is conducted. The increased speed and mobility of business activities and cross-border transactions has particular implications for applying transfer pricing methods and for taxing business profits. E-commerce: Transfer Pricing and Business Profits presents
A summary note of the 2nd Annual CTPA Roundtable which took place on January 26-27, 2005 and which focused on the tax implications of cross-border business restructuring.
Outline of the 2nd Annual CTPA Roundtable focused on business restructing, which took place on in Paris on 26-27 January 2005.
An information note concerning the International Tax Conference, organised in Washington on 13-14 January 2005 to discuss international tax issues and related OECD initiatives.
English, , 498kb
The OECD has released an analytical study of transfer pricing issues in respect of employee stock option plans. This study was prepared by the OECD Secretariat and benefited from considerable input and detailed discussions from the Delegates to the Working Party No. 6 on the Taxation of Multinational Enterprises of the Committee on Fiscal Affairs. When developing this Study, the OECD Secretariat also received formal and informal input
English, , 393kb
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.
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...