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The arm’s length principle of Art. 9 of the Model Tax Convention is based on comparisons of the conditions of controlled and uncontrolled transactions. Practical guidance on comparability analysis and on the OECD authorised transfer pricing methods (whether traditional transaction methods or transactional profit methods) is found at Chapters I-III of the 1995 Transfer Pricing Guidelines. The OECD is currently reviewing its guidance on comparability analysis and on the application of transactional profit methods (i.e., the profit split methods and the transactional net margin method).
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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).
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13-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 since the adoption of the Transfer Pricing Guidelines in 1995 and on comments received from the business community in response to an open questionnaire release in 2003.
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18-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 Enterprises and Tax Administrations. Numerous contributions have now been received and will be carefully examined by Working Party No. 6 on the Taxation of Multinational Enterprises.
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The OECD's Guidelines on dealing with commercial transactions between different parts of a multinational group.
Transfer Pricing Guidelines
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