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Transfer pricing

Transfer Pricing - Working Papers

 

Public comments received on the administrative aspects of transfer pricing

08-Jul-2011

8 July 2011 - On 9 March 2011, the OECD released an invitation to comment on the administrative aspects of transfer pricing. This was followed on 10 June 2011 by the release of a document containing a ...

OECD releases a Multi-Country Analysis of Existing Transfer Pricing Simplification Measures - 10 June 2011

10-Jun-2011

10-June-2011: OECD releases a Multi-Country Analysis of Existing Transfer Pricing Simplification Measures.

The taxation of global trading financial instruments: A discussion draft

31-May-2011

A discussion draft, prepared by the Special Sessions on Innovative Financial Transactions in January 1997.

OECD invites comments on new project on the administrative aspects of transfer pricing

07-Mar-2011

9 March 2011 - The OECD’s Committee on Fiscal Affairs has launched a new project on the administrative aspects of transfer pricing. This work is regarded as important to strike a balance between the development ...

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

27-Jan-2011

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

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

02-Jul-2010

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.

Public comments on the revised draft of the new Article 7 of the OECD Model Tax Convention

28-Jan-2010

The OECD has published the comments received on a proposed draft of the new Article 7 of the Model Tax Convention.

Public comments on the proposed revision of Chapters I-III of the Transfer Pricing Guidelines

13-Jan-2010

In September 2009, the OECD released for public comment a proposed revision of Chapters I-III of itsTransfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. The comments recieved have now been published.

OECD releases a proposed revision of Chapters I-III of the Transfer Pricing Guidelines

09-Sep-2009

On 9 September, the OECD released for public comment a proposed revision of Chapters I-III of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations

Revision of Chapters I-III of the Transfer Pricing Guidelines

09-Sep-2009

On 9 September, the OECD released for public comment a proposed revision of Chapters I-III of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.

Public comments on the Transfer Pricing Aspects of Business Restructurings

06-Mar-2009

On 19 September 2008, the OECD Committee on Fiscal Affairs released for comment a discussion draft on the  Transfer Pricing Aspects of Business Restructurings<

Transactional profit methods : discussion draft for public comment

25-Jan-2008

As part of its monitoring of the implementation of the 1995 Transfer Pricing Guidelines, Working Party No. 6 of the OECD Committee on Fiscal Affairs is examining the application of transactional profit methods.<

Discussion draft released on Part IV (Insurance) of Report on Attribution of Profits to Permanent Establishments (revised)

22-Aug-2007

The OECD Committee on Fiscal Affairs has today published a revised public discussion draft of Part IV (Insurance) of its Report on the Attribution of Profits to Permanent Establishments. The revised draft replaces the original draft of Part IV released in June 2005.

OECD releases parts I-III of report on attribution of profits to permanent establishments and updates status of project

21-Dec-2006

The OECD published the new versions of Parts I (General Considerations), II (Banks) and III (Global Trading) of the Report on Attribution of Profits to Permanent Establishments, along with an update of ...

Comparability: Business comments on the OECD discussion draft

14-Dec-2006

On 10 May 2006, the OECD released a series of draft issues notes on comparability that was developed by the Committee on Fiscal Affairs' Working Party No. 6, building on experience acquired by countries ...

Transactional Profit Methods: Responses to the OECD Invitation to Comment

06-Sep-2006

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 ...

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

10-May-2006

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 ...

OECD invites comments on the application of transactional profit methods

28-Feb-2006

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 ...

Attribution of Profits to a Permanent Establishment: Revised discussion draft for public comment

03-Aug-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 ...

Discussion Draft on the Attribution of Profits to Permanent Establishment - Part I (General Considerations)

03-Aug-2004

A revised discussion draft of Part 1 (General) for public comments.  Written comments should be submitted no later than 28 September 2004.

Business Profits Technical Advisory Group Report

28-Nov-2003

This discussion draft reflects the work and preliminary conclusions of the OECD Technical Advisory Group (TAG).

Transfer Pricing: The OECD launches an invitation to comment on comparability issues; public comments received

29-Apr-2003

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.

Attribution of Profits to a Permanent Establishment (PE): the OECD releases two further Discussion Drafts for public comment on 4 March 2003

04-Mar-2003

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 ...

Discussion Draft on the Attribution of Profits to Permanent Establishments: Part III (Global Trading of Financial Instruments

04-Mar-2003

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", ...

The Tax Treatment of Employee Stock-Options

06-Mar-2002

Employee stock-option schemes are growing in importance across the OECD and this raises a number of issues for both domestic and international tax policy. In view of this, the OECD's Committee on Fiscal ...

Les problèmes de fiscalité internationale posés par les options d'achat d'actions pour les salariés : Document pour discussion publique

01-Mar-2002

The OECD has undertaken work on a number of cross-border issues related to employee stock-options. Interested parties are invited to send their comments on this note before 31 July 2002.

Discussion Draft: Attribution of Profit to a Permanent Establishment

08-Feb-2001

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 ...

 

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