OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations: 2010

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 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 tr

The OECD s Task Force on Tax and Development has begun a programme of support for developing countries seeking to implement or strengthen their transfer pricing rules Read What s New Transfer Pricing Documentation and Country by OECD This report contains revised standards for transfer pricing documentation incorporating a master file, local file, and a template for country by country reporting of revenues, profits, taxes paid and certain measures of economic activity. OECD Transfer pricing country profiles KPMG GLOBAL OECD Transfer pricing country profiles add new profiles OECD Transfer pricing country profiles The Organisation for Economic Cooperation and Development OECD published new transfer pricing country profiles for countries Australia, China, Estonia, France, Georgia, Hungary, India, Israel, Liechtenstein, Norway, Poland, Portugal, Sweden, and Uruguay. OECD seven new transfer pricing country profiles KPMG OECD New transfer pricing country profiles OECD seven new transfer pricing country profiles The Organisation for Economic Cooperation and Development OECD today announced the release of new transfer pricing country profiles for Costa Rica, Greece, South Korea, Panama, Seychelles, South Africa, and Turkey, and announced that the information in the transfer pricing country profile for Singapore OECD releases new guidance on transfer pricing for low This Alert discusses the revisions to Chapter VII of the OECD Transfer Pricing Guidelines on intra group services The main focus of the revision is the new Section D containing additional guidance with respect to an elective, simplified transfer pricing approach for low value adding intra group services. OECD Transfer Pricing Guidelines New version The OECD Transfer Pricing Guidelines for Multinational Enterprise 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 OECD Releases Edition of Transfer Pricing Guidelines On July , , the OECD released its version of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations TP Guidelines , which provide guidance on the application of the arm s length principle The TP Guidelines define the arm s length

  • Title: OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations: 2010
  • Author: Organisation for Economic Co-operation and Development
  • ISBN: 9789264090330
  • Page: 124
  • Format: Paperback
  • 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 MNThe 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 The OECD Transfer Pricing Guidelines were approved by the OECD Council in their original version in 1995 A limited update was made in 2009, 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 In the 2010 edition, 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 Further, a new Chapter IX, on the transfer pricing aspects of business restructurings, was added Consistency changes were made to the rest of the Guidelines.

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