Transfer Pricing and Multinational Enterprises Three Taxation Issues
Author | : OECD |
Publisher | : OECD Publishing |
Total Pages | : 90 |
Release | : 1984-10-01 |
Genre | : |
ISBN | : 9264167803 |
Digitised document - Electronic release on 24/11/2011
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Author | : OECD |
Publisher | : OECD Publishing |
Total Pages | : 90 |
Release | : 1984-10-01 |
Genre | : |
ISBN | : 9264167803 |
Digitised document - Electronic release on 24/11/2011
Author | : OECD |
Publisher | : OECD Publishing |
Total Pages | : 107 |
Release | : 1979-06-01 |
Genre | : |
ISBN | : 9264167773 |
The OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations provide guidance on the application of the “arm’s length principle”, which is the international consensus on transfer pricing, i.e. on the valuation, for tax purposes, of cross-border transactions between associated enterprises. In a global economy where multinational enterprises (MNEs) play a prominent role, transfer pricing is high on the agenda of tax administrators and taxpayers alike. Governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdictions and that the tax base reported by MNEs in their respective countries reflect the economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation that may result from a dispute between two countries on the determination of an arm’s length remuneration for their cross-border transactions with associated enterprises. Following this original 1979 publication, the OECD Transfer Pricing Guidelines were approved by the OECD Council in their original version in 1995. A limited update was made in this 2009 edition, primarily to reflect the adoption, in the 2008 update of the Model Tax Convention, of a new paragraph 5 of Article 25 dealing with arbitration, and of changes to the Commentary on Article 25 on mutual agreement procedures to resolve cross-border tax disputes. A subsequent edition was released in 2010, in which, Chapters I-III were substantially revised, with new guidance on: the selection of the most appropriate transfer pricing method to the circumstances of the case; the practical application of transactional profit methods (transactional net margin method and profit split method); and on the performance of comparability analyses. Furthermore, a new Chapter IX, on the transfer pricing aspects of business restructurings, was added. Consistency changes were made to the rest of the Guidelines. Digitised document - Electronic release on 24/11/2011.
Author | : Organisation for Economic Co-operation and Development. Committee on Fiscal Affairs |
Publisher | : |
Total Pages | : 91 |
Release | : 1984 |
Genre | : International business enterprises |
ISBN | : |
Author | : |
Publisher | : |
Total Pages | : |
Release | : 1984 |
Genre | : Taxation |
ISBN | : |
Digitised document - Electronic release on 24/11/2011.
Author | : Organización de Cooperación y Desarrollo Económicos |
Publisher | : |
Total Pages | : 91 |
Release | : 1992 |
Genre | : |
ISBN | : |
Author | : OECD |
Publisher | : OECD Publishing |
Total Pages | : 192 |
Release | : 2017-07-31 |
Genre | : |
ISBN | : 9264279962 |
Author | : OECD |
Publisher | : OECD Publishing |
Total Pages | : 247 |
Release | : 2009-08-18 |
Genre | : |
ISBN | : 9264075348 |
OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations provides guidance on the valuation for tax purposes of cross-border transactions between associated enterprises.
Author | : Organisation for Economic Co-operation and Development. Committee on Fiscal Affairs |
Publisher | : |
Total Pages | : 75 |
Release | : 1984 |
Genre | : |
ISBN | : |
Author | : OECD |
Publisher | : OECD Publishing |
Total Pages | : 612 |
Release | : 2017-07-10 |
Genre | : |
ISBN | : 9264265120 |
This consolidated version of the OECD Transfer Pricing Guidelines includes the revised guidance on safe harbours adopted in 2013, as well as the recent amendments made by the Reports on Actions 8-10 and 13 of the BEPS Actions Plan and conforming changes to Chapter IX.
Author | : OECD |
Publisher | : OECD Publishing |
Total Pages | : 375 |
Release | : 2010-08-16 |
Genre | : |
ISBN | : 9264090185 |
The OECD Transfer Pricing Guidelines provide guidance on the application of the “arm’s length principle”, which is the international consensus on transfer pricing, the valuation, for tax purposes, of cross-border transactions between associated enterprises.