Transfer pricing

OECD invites comments on the application of transactional profit methods


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

  • Comparability issues encountered when applying the transfer pricing methods authorised by the 1995 TP Guidelines (whether traditional transaction methods or transactional profit methods) and
  • The application of transactional profit methods (i.e., the profit split methods and the transactional net margin method which are described in Chapter III of the 1995 TP Guidelines). It is expected that the ultimate outcome of the review of transactional profit methods should be a revision of Chapter III of the 1995 TP Guidelines.


We believe it is essential for our work to benefit from input from the business community and from other interested non-governmental parties.


In April 2003, the public was invited to comment on issues in relation to comparability (see invitation to comment and comments received). The Working Party has been working on a series of Issues notes that will be released for public comment in the first half of 2006.


Comments on issues related to profit methods were invited from the Business and Industry Advisory Committee (BIAC). The OECD is now issuing an open invitation to contribute on a number of issues in relation to transactional profit methods.


Please do not hesitate to contact us should you have any questions. Responses should be sent either by fax, mail or e-mail to the following address by 31 August 2006:


Caroline Silberztein - CTP/TTP
Head of the Transfer Pricing Unit
OECD Centre for Tax Policy and Administration
2, rue André-Pascal 75775 Paris Cedex 16
Fax: 33 (0)1 44 30 63 13
E-mail: and copied to