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Transfer Pricing
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OECD News and Other Resources
OECD Dealing
Effectively with the Challenges of Transfer Pricing
This report is concerned with the practical administration of transfer
pricing programs by tax administrations. It discusses ways in which the
management of transfer pricing programs can be optimized, so that transfer
pricing audits and enquiries are conducted efficiently and in a timely
manner. It is concerned with the practical steps tax administrations need to
take to correctly identify transfer pricing cases that merit audit or
enquiry and then to progress those cases to as early a conclusion as
possible.
January 2012
OECD's Multi-Country Analysis of Existing Transfer Pricing Simplification
Measures
The OECD launched in 2010 a project on the
administrative aspects of transfer pricing, including a review of techniques
that may be implemented by countries to optimize the use of taxpayers’ and
tax administrations’ resources while improving the compliance and
enforcement climate. Transfer pricing simplification measures existing in 33
OECD and non-OECD economies were identified and analyzed.
June 10, 2011
OECD Meets with Business Commentators on the Valuation of Intangibles for
Transfer Pricing Purposes
Representatives and officials from OECD and
non-OECD countries met to discuss a method for the valuation of intangibles.
March 29, 2011
OECD
Releases Scoping Document for its New Project on the Transfer Pricing
Aspects of Intangibles
The OECD believes that the development of
clearer and consensus based international guidance on the transfer pricing
aspects of intangibles could help limit uncertainty and risks. The Committee
on Fiscal Affairs has decided to start in 2011 a new project on the transfer
pricing aspects of intangibles.
January 27, 2011
Public Comments on the Scoping of a New Project on the Transfer Pricing
Aspects of Intangibles
The OECD will start a new project in 2011 on the
Transfer Pricing Aspects of Intangibles and has invited comments from
interested parties on the scoping of such a project.
The OECD has now published the comments received.
September 23, 2010
OECD's 6th Meeting on Tax Administration - Joint Audit Report
This report was commissioned by the Forum on Tax
Administration (FTA) and sets out the findings and recommendations based on
a project to examine how international cooperation could be advanced through
the use of joint audits among Participating Countries.
September 15/16, 2010
OECD Approves the 2010 Transfer Pricing Guidelines
Chapters I-III were revised as a result of the
review of comparability and profit methods that was undertaken by the OECD,
with input from non OECD economies. New guidance was developed on the
selection of the most appropriate transfer pricing method to the
circumstances of the case, the practical application of transactional profit
methods (the transactional net margin method and the profit split method)
and the performance of comparability analyses.
In addition, the 2010 version of the Transfer
Pricing Guidelines contains a new Chapter IX on the transfer pricing aspects
of business restructurings. .
July 22, 2010
African Tax Administration Forum
A new forum designed to improve tax transparency
and administration in African states. Its mission is to mobilize domestic
tax resources more effectively. The forum aims to enhance cooperation
between states and to improve benchmarking and peer review procedures.
November 18-20, 2009
OECD Releases a Proposed Revision of Chapters I - III of its Transfer
Pricing Guidelines
The OECD released for public comment a proposed
revision of Chapters I – III of its Transfer Pricing Guidelines for
Multinational Enterprises and Tax Administrations. This represents an
important update of the existing guidance on comparability and profit
methods which dates back to 1995. The main proposed changes discuss the
hierarchy of transfer pricing methods, comparability analysis, and guidance
on the application of transactional profit methods.
September 9, 2009
OECD Releases the 2009 Edition of its Transfer Pricing Guidelines
The OECD released the 2009
edition of its Transfer Pricing Guidelines for Multinational Enterprises
and Tax Administrations. This edition incorporates an update of Chapter
IV to reflect the latest developments in the area of dispute resolution as
well as updates to the Foreword, Preface and Council Recommendation.
September 7, 2009
OECD Opens Registration for Conference in Paris: "Transfer Pricing and
Treaties in a Changing World
The OECD has opened registration for its
Conference, which will take place in Paris (at the OECD’s conference center)
on September 21-22, 2009. Specialists will share their expertise on
transfer pricing and treaty developments that affect governments and
multinational enterprises in a changing world. Topics will include the
role of Articles 7, 9 and 25 of the Model Tax Convention; documentation
requirements, exchange of information and burden of proof issues;
deductibility of interest in related party situations; transfer pricing in a
downturn economy; attribution of profits to Permanent Establishments and
designing a modern Article 7; transfer pricing and customs; treaty and
transfer pricing aspects of intangibles characterization; and recent
developments in the areas of transfer pricing and treaties.
April 8, 2009
OECD Releases Public Comments on the Transfer Pricing Aspects of Business
Restructurings
On September 19, 2008, the OECD Committee on
Fiscal Affairs released for comment a discussion draft on the
Transfer Pricing Aspects of Business Restructurings. The above
link provides the public comments related to the subject draft.
March 6, 2009
OECD Holds Consultation with Business on Comparability and Profit Methods
for Transfer Pricing Purposes
During the consultation, participants discussed
a broad range of fundamental and practical issues in relation to the
comparability analysis, the selection of the most appropriate transfer
pricing method to the circumstances of a case, and the practical application
of transactional profit methods.
November 19, 2008
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
Comparability: Public Invitation to Comment on a Series of Draft Issues
Notes
This document provides issues notes on the
following topics:
A – Putting a Comparability Analysis and Search
for Comparables into Perspective
B – Timing Issues in Comparability
C – Internal Comparables
D – Determination of Available Sources of Information and of Their
Reliability
E – Uncontrolled Transactions
F – Examining the Five Comparability Factors
G – Selecting or Rejecting Third Parties or Third-Party Transactions: Degree
of Objectivity of the List of External Comparables
H – Determination of and Making Comparability Adjustments Where Appropriate
I – Multiple-Year Data
J – Aggregation of Transactions
K – Other Topics Discussed
May 10, 2006
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