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ISBN: 978-92-64-07527-6
softcover 247 pages
(includes electronic PDF format version- Emailed to client at time of order)
Price $81.00
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10-19 copies 10% discount
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OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations provides guidance on the application of the “arm’s length principle” for valuation for tax purposes of cross-border transactions between associated enterprises.
In a global economy where multinational enterprises (MNEs) play a prominent role, governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdiction and that the tax base reported by MNEs in their country reflects 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 the arm’s length remuneration for their cross-border transactions with associated enterprises.
The OECD Transfer Pricing Guidelines clarifies these issues and were originally approved by the OECD Council in 1995. In this 2009 edition, some amendments have been made to Chapter IV, 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. References to good practices identified in the online Manual for Effective Mutual Agreement Procedures (www. oecd.org/ctp/memap) have also been included and the foreword and preface have been updated.These Guidelines are a revision of the OECD Report Transfer Pricing and Multinational Enterprises (1979).
They were approved in their original version by the Committee on Fiscal Affairs on 27 June 1995 and by the OECD Council for publication on 13 July 1995.
Since their original version, these Guidelines have been supplemented:
• by the report on intangible property and services, adopted by the Committee
on Fiscal Affairs on 23 January 1996 [DAFFE/CFA(96)2] and noted by the Council on 11 April 1996 [C(96)46], incorporated in Chapters VI and VII;
• by the report on cost contribution arrangements, adopted by the Committee on Fiscal Affairs on 25 June 1997 [DAFFE/CFA(97)27] and noted by the Council on 24 July 1997 [C(97)144], incorporated in Chapter VIII;
• by the report on the guidelines for monitoring procedures on the OECD Transfer Pricing Guidelines and the involvement of the business community [DAFFE/CFA/WD(97)11/REV1], adopted by the Committee on Fiscal Affairs on 24 June 1997 and noted by the Council on 23 October 1997 [C(97)196], incorporated in the Annexes; and
• by the report on the guidelines for conducting advance pricing arrangements under the mutual agreement procedure, adopted by the Committee on Fiscal Affairs on 30 June 1999 [DAFFE/CFA(99)31] and noted by the Council on 28 October 1999 [C(99)138], incorporated in the Annexes.
In addition, these Guidelines have been modified by an update of Chapter IV which was adopted by the Committee on Fiscal Affairs on 6 June 2008 [CTPA/CFA(2008)30/REV1] and by an update of the Foreword and of the Preface adopted by the Committee on Fiscal Affairs on 22 June 2009 [CTPA/CFA(2009)51/REV1]; these updates were approved by the Council on 16 July 2009 [C(2009)88].
These Guidelines will continue to be supplemented with additional guidance addressing other aspects of transfer pricing and will be periodically reviewed and revised on an ongoing basis.
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