Transfer pricing

Transfer Pricing: The OECD launches an invitation to comment on comparability issues; public comments received


As part of its procedures for monitoring the implementation of the 1995 Transfer Pricing Guidelines ("the 1995 TP Guidelines"), the Working Party No. 6 of the OECD Committee on Fiscal Affairs has selected two areas to be considered in priority.

  • The application of transactional profit methods (i.e. the transactional profit split methods and the transactional net margin method) and
  • Comparability issues encountered when applying the transfer pricing methods authorised by the 1995 TP Guidelines (whether traditional transaction methods or transactional profit methods).


As a first step, we are issuing an open invitation to comment on comparability issues. An invitation to comment on issues related to profit methods will be issued later.


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Comments Received


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