Transfer Pricing Resources for the OECD

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OECD Transfer Pricing Country Profiles

OECD News and Other Resources

 

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OECD Transfer Pricing Country Profiles 

Main Page of Country Profiles
Link to main page of country profiles with latest updates.

 -- Argentina  -- Japan
 -- Australia  -- Korea
 -- Belgium  -- Mexico
 -- Canada  -- The Netherlands
 -- Chile  -- New Zealand
 -- Czech Republic  -- Norway
 -- Denmark  -- Poland
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 -- France  -- Slovak Republic
 -- Greece  -- Spain
 -- Hungary  -- Sweden
 -- Ireland  -- United Kingdom
 -- Italy  -- United States

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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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