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.
Description of OECD Structural Analysis Statistics Online Database.
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
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.
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Members have updated their responses to the 2006 Survey on measures taken to combat bribery in officially supported export credits.
The OECD Factbook is the best-selling, innovative title from the OECD. It provides a global overview of today’s major economic, social and environmental indicators, presenting them clearly and concisely, and in a range of user-friendly formats.
In developing a stronger focus on agricultural biomass crops, governments will have to design support policies so as to avoid compromising the ability of the agricultural sector to provide food and feed in a sustainable manner, this study finds.
Country case studies of China, Japan, Netherlands, South Africa and the United States in measures that may hamper trade in steel scrap, recovered paper and plastic scrap, and if and how they could be removed without compromising environmental protection.
Trade in steel scrap, recovered paper and plastic scrap is well developed and plays an important role in fostering environmentally sound recycling of these materials. This report assesses options for promoting trade and recycling of these non-hazardous materials.
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Members have updated their responses to the 2007 Survey on the environment and officially supported export credits.