E-commerce: Transfer Pricing and Business Profits Taxation
OECD Tax Policy Studies Series No. 10
|Language||English; Aussi disponible en français|
Published by the Organisation for Economic Co-operation and Development, 2005.
|The increased speed and
mobility of business activities and cross-border transactions resulting from
internet usage has particular implications for applying transfer pricing
methods and for taxing business profits. E-Commerce: Transfer Pricing and
Business Profits Taxation, presents a two-part look at existing OECD
positions on these issues.
Part I of this edition analyzes e-commerce transfer pricing in the context of four business models: automated electronic transactions; online auctions for customer-to-customer and business-to-business sales; subsidiary-to-parent web hosting arrangements; and computerized transactions for airline reservations. The OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations provide guidance on the application of the arms length principle to transfer pricing methods. Part I assesses how appropriate this guidance is to the issues raised by e-commerce.
Part II of this edition examines the current OECD Model Tax Convention treaty rules for taxing business profits. It studies whether the existing rules are capable of dealing with the new reality of e-commerce in a fair and effective manner and whether it could be possible to find better alternatives.
E-Commerce: Transfer Pricing and Business Profits Taxation is the tenth volume of the series OECD Tax Policy Studies.
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