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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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from 09-Sep-2009 to 09-Jan-2010
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. This follows from the release in May 2006 of a discussion draft on comparability issues and in January 2008 of a discussion draft on transactional profit methods, and from discussions with commentators during a two-day consultation that was held in November 2008. Interested parties are invited to submit comments by 9 January 2010 to Jeffrey Owens, Director,CTPA (jeffrey.owens@oecd.org).
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09-Sep-2009
On 7 September 2009, the OECD released the 2009 edition of its Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. This edition incorporates an update of Chapter IV to reflect the latest developments in the area of dispute resolution as well as updates to the Foreword, Preface and Council Recommendation. It was released in time for the Conference Transfer Pricing and Treaties in a Changing World.
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19-Nov-2008
On 17-18 November 2008, the OECD held a consultation with business commentators on comparability and profit methods for transfer pricing purposes. The consultation followed the release of two discussion drafts on comparability (May 2006) and transactional profit methods (January 2008) under the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, both of which attracted very detailed responses from the business community.
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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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