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E-commerce: Transfer Pricing and Business Profits Taxation

OECD Tax Policy Studies Series No. 10

E-commerce: Transfer Pricing and Business Profits Taxation    
Format Softcover
Catalogue No. 232005031P
Pages 164
Language English; Aussi disponible en français
Price $50.60

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 arm’s 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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This page last modified: February 20, 2008

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