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A large share of world trade consists of transfer of goods, intangibles and services within multinational enterprises. To determine tax liability in each jurisdiction, the right arm's length principle has to be applied. The OECD has issued Transfer Pricing Guidelines on this principle to avoid double taxation.
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19-Nov-2008
On 17-18 November 2008, the OECD held a consultation with business commentators on comparability and profit methods for transfer pricing purposes. The consultation followed the release of two discussion drafts on comparability (May 2006) and transactional profit methods (January 2008) under the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, both of which attracted very detailed responses from the business community.
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19-Sep-2008
On 19 September 2008, the Committee on Fiscal Affairs released for public comment a discussion draft on the transfer pricing aspects of business restructurings. Comments should be sent before 19 February 2009 to Jeffrey Owens, Director, CTPA (jeffrey.owens@oecd.org).
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18-Jul-2008
On 17 July 2008, the OECD Council approved the release of the final Report on the Attribution of Profits to Permanent Establishments. An interim version of Parts I-III of the Report had previously been released in December 2006, and a discussion draft version of Part IV was released in August 2007. The Report was subsequently finalised and approved by the Committee on Fiscal Affairs on 24 June 2008.
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from 07-Jul-2008 to 31-Dec-2008
On 24 June 2008, the Committee on Fiscal Affairs approved the Report on Attribution of Profits to Permanent Establishments. It also approved the release, for public comment, of the second part of the implementation package for the conclusions of that Report, i.e. a new version of Article 7 and its Commentary. This new Article and related Commentary changes are now being released as a discussion draft for public comment. Comments should be sent before 31 December 2008 to Jeffrey Owens, Director, CTPA (jeffrey.owens@oecd.org).
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25-Jan-2008
More than 250 participants met in Mumbai, India, on 23-25 January 2008 to discuss a broad range of international tax issues at the Conference “At the Crossroads of Tax Co-operation: IFA (India) – OECD” that was jointly organized by the Indian Branch of the International Fiscal Association (IFA) and the Organisation for Economic Co-operation and Development (OECD) to mark the accession of India as observer to the OECD Committee on Fiscal Affairs.
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25-Jan-2008
The OECD is issuing an invitation to comment on a series of issues notes that was drafted by the Committee on Fiscal Affairs' Working Party No. 6, building on experience acquired by countries in applying transactional profit methods since the adoption of the Transfer Pricing Guidelines in 1995 and on comments received from the business community.
Comments may be submitted by 30 April 2008 to Jeffrey Owens, Director, CTPA (jeffrey.owens@oecd.org).
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The OECD's Guidelines on dealing with commercial transactions between different parts of a multinational group.
Transfer Pricing Guidelines
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The Taxation of Employee Stock Options
