OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2010
|Format||Softcover - PDF version available on request when you purchase the softcover|
|Language||English; Aussi disponible en français|
Published by the Organisation for Economic Co-operation and Development, 2010.
|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
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 analyzes. Furthermore, 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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This page last modified: September 23, 2010
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