Transfer pricing

The OECD pursues dialogue with business on business restructuring issues


The OECD pursues its dialogue with the business community on the transfer pricing and treaty aspects of Business Restructurings.

The OECD participated in discussion panels on business restructurings at the OECD / USCIB Tax Conference “New OECD International Tax Initiatives: Looking Ahead” held in Washington on 4 and 5 June 2007 and at the OECD / BIAC seminar “Tax Efficiency and Business Reorganisation: Designing Pro-Growth Tax Systems” that took place in Stockholm on 28 and 29 May 2007. On these occasions, the Secretariat described the process, objectives, timeline and current state of affairs of the project. See presentation material from Jeffrey Owens – Director of the OECD Centre for Tax Policy and Administration at the Stockholm conference.

The Business Advisory Group met for the third time in Paris on 11 June 2007, together with government representatives involved in the OECD project on Business Restructurings. Topics for discussion were the transfer pricing consequences of restructurings and permanent establishments issues (the second and the third broad areas of work identified in the mandate for the Joint Working Group on Business Restructurings). Click here for the meeting agenda.

The Joint Working Group on Business Restructurings is still at the stage of formulating its policy view on the various issues identified in its mandate, and the public is invited to note that the fact that an issue is identified for discussion does not mean that any final or even tentative position has been arrived at by the OECD, nor does it signal a direction the project is likely to take. As soon as the OECD has a discussion draft ready (currently projected for late 2008), the draft will be released to the public for comment. In the meantime, any interested parties who wish to provide input on the issues that are within the Working Group's mandate are free to submit comments to the OECD Secretariat by writing to Caroline Silberztein, Head of the Transfer Pricing Unit, Division of Tax Treaties, Transfer Pricing and Financial Transactions, Centre for Tax Policy and Administration (


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