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Transfer Pricing
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OECD
Transfer Pricing Country Profiles
OECD News and Other
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OECD News and Other Resources
Discussion Draft on the Transfer Pricing Aspects of Business Restructurings
A release for public comment
on the transfer pricing aspects of business restructurings. Comments should
be sent before February 19, 2009.
September 19, 2008
2008 Update to the OECD Model Tax Convention
Incorporates contents on improving the
resolution of tax treaty disputes, revises commentary on Article 7 related
to permanent establishments, applies and interprets Article 24, discusses
tax treaty issues related to REITs and the tax treaty treatment of services.
July 18, 2008
Response of the Committee on Fiscal Affairs to
the Comments Received on the April Discussion Draft on the 2008 Update to
the Model Tax Convention
The Committee carefully examined the
comments received and after extensive review of these comments concluded
that no major additional changes should be made to the update. It did,
however, agree that a number of useful clarifying changes were proposed and
that these should be included in the update. In addition, a few issues
raised in the comments have been identified as requiring further work. The
attached provides a brief description of the comments received and the
Committee’s response to some of them.
July 18, 2008
OECD Releases
Final Report on the Attribution of Profits to Permanent Establishments
The Report provides guidance on the principles
for attributing profits to a permanent establishment under Article 7 of the OECD
Model Tax Convention on Income and Capital. It reflects the results of
work undertaken to examine how the principles developed in the OECD's
Transfer Pricing Guidelines for application to separate but associated
enterprises should apply in the context of the relationship
between a permanent establishment and the rest of the enterprise to which it
belongs.
July 17, 2008
Public Comments on Draft Contents of the 2008 Update to the Model Tax
Convention
On April 21, 2008, the OECD Committee on Fiscal
Affairs published the draft contents of the 2008 Update to the Model Tax
Convention. The OECD has published the comments received on that draft. The
attached link include comments received by the OECD on the revised draft.
June 9, 2008
OECD Releases Public Comments on Transactional Profit Methods Issues Notes
On January 25, 2008, the OECD released an
invitation to comment on a series of draft issues notes in relation to
transactional profit methods (i.e., the transactional profit split and
the transactional net margin methods). The comments received by the OECD can
be downloaded from the links attached.
May 7, 2008
Tackling Cross Border Tax Evasion
Joint Press Statement of Mr. Angel Gurría, OECD
Secretary-General and Ms. Kristin Halvorsen, Norwegian Minister of Finance.
March 6, 2008
OECD Invites Comments on the Application of Transactional Profit Methods
January 25, 2008
Transfer Pricing, Customs Duties, and VAT Rules: Can We Bridge the Gap?
Liu Ping, World Customs Organisation, and
Caroline Silberztein, OECD Centre for Tax Policy and Administration
September 11, 2007
OECD Releases Revised Draft of Part IV (Insurance) of Report on Attribution
of Profits to Permanent Establishments
Discussion draft on how insurance companies
should attribute profits to a permanent establishment, substantially
revising the section on reinsurance and amending the definition of key
entrepreneurial risk-taking (KERT) functions.
August 23, 2007
The OECD Pursues Dialogue with Business on Business Restructuring Issues
June 18, 2007
Second WCO-OECD Conference, May 22-23, 2007: Closing Remarks
June 1, 2007
Revised Commentary on Article 7 of the OECD Model Tax Convention
April 10, 2007
Improving the Resolution of Tax Treaty Disputes
Release of OECD's procedure for mandatory
arbitration of competent authority disputes that would give taxpayers the
right to litigate their disputes if they are dissatisfied with the outcome.
February 2007
The Tax Treaty Treatment of Services: Proposed Commentary Changes
Proposal to include alternative language in the
Model Tax Treaty's Commentary to allow nations to tax services.
December 8, 2006
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