Transfer Pricing

A large share of world trade consists of transfer of goods, intangibles and services within multinational enterprises. To determine tax liability in each jurisdiction, the right arm's length principle has to be applied. The OECD has issued Transfer Pricing Guidelines on this principle to avoid double taxation.

What's new

OECD releases public comments on transactional profit methods issues notes

07-May-2008

On 25 January 2008, the OECD released an invitation to comment on a series of draft issues notes in relation to transactional profit methods (i.e., the transactional profit split and the transactional net margin methods).
 

Joint OECD - IFA (India) Conference "At the Crossroads of Tax Co-operation" held in Mumbai, 23-25 January 2008

25-Jan-2008

More than 250 participants met in Mumbai, India, on 23-25 January 2008 to discuss a broad range of international tax issues at the Conference “At the Crossroads of Tax Co-operation:  IFA (India) – OECD” that was jointly organized by the Indian Branch of the International Fiscal Association (IFA) and the Organisation for Economic Co-operation and Development (OECD) to mark the accession of India as observer to the OECD Committee on Fiscal Affairs.

OECD invites comments on the application of transactional profit methods

25-Jan-2008

The OECD is issuing an invitation to comment on a series of issues notes that was drafted by the Committee on Fiscal Affairs' Working Party No. 6, building on experience acquired by countries in applying transactional profit methods since the adoption of the Transfer Pricing Guidelines in 1995 and on comments received from the business community.
Comments may be submitted by 30 April 2008 to Jeffrey Owens, Director, CTPA (jeffrey.owens@oecd.org).

Public comments on revised draft of Part IV (Insurance) of Report on Attribution of Profits to Permanent Establishments

06-Nov-2007

On 22 August 2007, the OECD Committee on Fiscal Affairs published a revised public discussion draft  of Part IV (Insurance) of its Report on the Attribution of Profits to Permanent Establishments. The OECD has now published the comments received on that draft.

 

Transfer Pricing, Customs Duties and VAT Rules: Can We Bridge the Gap?

11-Sep-2007

While the importance of transfer pricing is increasingly appreciated, the focus has traditionally been on direct taxation and transfer pricing still largely remains a subject for tax specialists. In the past decade, however, it has become obvious that the customs duties and, more recently, the VAT (value added tax) dimensions of transfer pricing can also take quite a toll on a company’s profits and on government revenues, and they are now increasingly attracting the attention of governments and businesses.

OECD releases revised draft of Part IV (Insurance) of Report on Attribution of Profits to Permanent Establishments

23-Aug-2007

On 22 August, the OECD Committee on Fiscal Affairs 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. Comments may be submitted  by 31 October 2007 to Jeffrey Owens, Director, CTPA (jeffrey.owens@oecd.org). A consultation meeting with interested commentators will be held on 26 November 2007.

Tax Reform in India – Achievement and Challenges

04-Jul-2007

Joint Press Briefing Notes by Pier Carlo Padoan, Deputy Secretary General, OECD to the International Tax Conference on "Tax Reform in India – Achievement and Challenges" that was held in Delhi on 3rd July 2007.

The OECD pursues dialogue with business on business restructuring issues

18-Jun-2007

The OECD pursues its dialogue with the business community on the transfer pricing and treaty aspects of Business Restructurings, participates in discussion panels in Washington and Stockholm, and convenes a third meeting of the Business Advisory Group.

Business Engages Top International Tax Officials at OECD Conference in Washington

07-Jun-2007

Nearly 300 U.S. and international executives, government officials and other tax experts convened at the Ronald Reagan Building and International Trade Center in Washington, D.C., for a major two-day conference, which highlighted the work of the OECD in the development of national tax policy and international tax arrangements governing cross-border trade and investment.

Second WCO-OECD conference, 22-23 May, 2007: Closing remarks

01-Jun-2007

2nd Joint WCO-OECD Conference on “Transfer Pricing and Customs Valuation of Related Party Transactions”, 22-23 May 2007.  See closing remarks .

International Conference on Transfer Pricing and Customs Valuation Brussels, 22-23 May 2007

22-May-2007

The World Customs Organization (WCO) and the OECD will hold a second international WCO/OECD Conference on Transfer Pricing and Customs Valuation, bringing together specialists in this complex field. The event will be held at the WCO headquarters in Brussels from 22-23 May 2007.

WCO/OECD - 2nd Joint Conference, 22-23 May 2007, WCO headquarters, Brussels

09-May-2007

2nd Joint WCO/OECD Conference: "Transfer Pricing, Indirect Taxes and VAT : Exploring possible convergences" - 22-23 May 2007, WCO headquarters, Brussels

Discussion draft on a revised Commentary on Article 7 (Business Profits) of the OECD Model Tax Convention

10-Apr-2007

In December 2006, the Committee on Fiscal Affairs released new versions of Parts I, II and III of its Report on the Attribution of Profits to Permanent Establishments, along with a cover note containing an update on the status of that project. In order to provide improved certainty for the interpretation of existing treaties based on the current text of Article 7, a revised Commentary has been prepared and is now being released as a discussion draft for public comment. Comments should be sent if possible before 15 June 2007 to Jeffrey Owens, Director, CTPA (jeffrey.owens@oecd.org).

Arbitration to be an option in cross-border tax disputes, OECD countries agree

07-Feb-2007

OECD countries have agreed to broaden the mechanisms available to companies and individuals involved in cross-border disputes over taxation by introducing the possibility of arbitration if other attempts to resolve disagreements fail.

OECD releases Part I-III of Report on the Attribution of Profits to Permanent Establishments and updates status of project

21-Dec-2006

The OECD Committee on Fiscal Affairs has today published new versions of Parts I, II and III of its Report on the Attribution of Profits to Permanent Establishments, along with a cover note containing an update on the status of the project.  The project, which has been underway for several years, is aimed at achieving a greater consensus on the manner of attributing profits to permanent establishments under Article 7 (Business Profits) of the OECD Model Tax Convention, with a primary goal of avoiding double taxation.

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Bookshop

The OECD's Guidelines on dealing with commercial transactions between different parts of a multinational group.

Transfer Pricing Guidelines

Report on the Attribution of Profits to Permanent Establishments Parts I (General Considerations) , II (Banks) and III (Global Trading)

Report on the Attribution of Profits to Permanent Establishments, Parts I-III

OECD Tax Policy Studies No. 11: The Taxation of Employee Stock Options

The Taxation of Employee Stock Options