The OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations provide guidance on the application of the “arm’s length principle”, which is the international consensus on transfer pricing, i.e. on the valuation, for tax purposes, of cross-border transactions between associated enterprises. In a global economy where multinational enterprises (MNEs) play a prominent role, transfer pricing is high on the agenda of tax administrators and taxpayers alike. Governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdictions and that the tax base reported by MNEs in their respective countries reflect the economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation that may result from a dispute between two countries on the determination of an arm’s length remuneration for their cross-border transactions with associated enterprises.
After having been originally published in 1979, the OECD Transfer Pricing Guidelines were approved by the OECD Council in their original version in 1995. A limited update was made in 2009, primarily to reflect the adoption, in the 2008 update of the Model Tax Convention, of a new paragraph 5 of Article 25 dealing with arbitration, and of changes to the Commentary on Article 25 on mutual agreement procedures to resolve cross-border tax disputes. In the 2010 edition, Chapters I-III were substantially revised, with new guidance on: the selection of the most appropriate transfer pricing method to the circumstances of the case; the practical application of transactional profit methods (transactional net margin method and profit split method); and on the performance of comparability analyses. Furthermore, a new Chapter IX, on the transfer pricing aspects of business restructurings, was added. Consistency changes were made to the rest of the Guidelines.
Private financial sector investment in agriculture has increased, mainly because of current prospects for income generation, capital appreciation, and uncorrelated returns with equity markets and as a hedge against inflation. This paper surveys this investment activity and its impacts.
To what extent do governments use international standards in their technical regulations? This paper looks at the electrical household appliance, natural gas equipment and telephony sectors in Canada, Japan, Korea, Mexico, United States and the European Union.
The Development Assistance Committee (DAC) is helping to tackle the challenge of how poorer countries can benefit more from trade and jointly with the WTO OECD will review self-assessment questionnaires sent to donors and partner countries.
Links to trade-related websites for Slovenia
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2010 Classification of countries according to per capita gross national income (GNI) to determine maximum repayment term and tied aid eligibility under the Arrangement, applicable as of 29 July 2010.
Description of OECD Structural Analysis Statistics Online Database.
Export restrictions on raw materials, including commodities like metals and minerals, are not always effective in meeting policy objectives and should be subject to greater transparency, says this OECD study of recent trends in these measures.
Aid for trade increases exports, creates jobs, boosts long-term economic growth and reduces poverty. Aid for trade increased 60% of the past 7 years, to USD 40 billion in 2009. The share to Africa and the Americas is growing fast, but dropping to Asia, Europe and Oceania.
In July 2010 the OECD and WTO issued a call for case stories on aid for trade. Over 300 stories from 150 countries (almost have from developing countries)worldwide provide a rich and varied source of information on the results of aid for trade activities - an indication of the progress achieved by the Aid-for-Trade Initiative. Consult the publication online and consult the case stories on www.aid4trade.org