Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations

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	Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations Travel version
	OECD. Published by : OECD Publishing

	Version: Print (Paperback) + Free PDF
	Price: €52 \| $72 \| £46 \| ¥6700 \| {72}{1}{5LMQCR2KLH9N}{72.00}

Availability: Low stock Publication date: 18 Jun 2001 Language: English Pages: 264 ISBN: 9789264186286 OECD Code: 232001041P1

Other Versions & Languages | Multilingual summaries | Table of contents

This compact version of Transfer Pricing Guidelines provides the complete and current text of the OECD pricing guidelines accepted by member countries and to be used by multinational enterprises when transferring goods and services across boundaries and within the same group of companies. They maintain the arm's length principle of treating related entreprises within a multinational group and affirm traditional transaction methods as the prefered way of implementing the principle. These controversial issues are not just of interest to tax experts. National tax administrations, taxpayers, and businessmen alike all have a share in avoiding conflicting tax rules which might seriously hamper the development of world trade.

These guidelines have also been published in a loose leaf version. The next revision will be available in 2009.

Other languages: French (Available (Print on Demand)) Hungarian (Distributed by another publisher) Croatian (Distributed by another publisher) Turkish (Available) Polish (Distributed by another publisher)

Other Versions: E-book - PDF Format

Multilingual summaries: Portuguese

Table of contents:

Preface
Glossary
Chapter I. The Arm's Length Principle
A. Introduction
B. Statement of the arm's length principle
C. Guidance for applying the arm's length principle
Chapter II. Traditional Transaction Methods
A. Introduction
B. Relationship to Article 9
C. Types of traditional transaction methods
Chapter III. Other Methods
A. Introduction
B. Transactional profit
C. A non-arm's-length approach:global formulary apportionment
Chapter IV. Administrative Approaches to Avoiding and Resolving Transfer Pricing Disputes
A. Introduction
B. Transfer pricing compliance practices
C. Corresponding adjustments and the mutual agreement procedure: Articles 9 and 25 of the OECD Model Tax Convention
D. Simultaneous tax examinations
E. Safe harbours
F. Advance pricing arrangements
G. Arbitration
Chapter V. Documentation
A. Introduction
B. Guidance on documentation rules and procedures
C. Useful information for effective transfer pricing audits
D. General recommendations on documentation
Chapter VI. Special Considerations for Intangible Property
A. Introduction
B. Commercial intangibles
C. Applying the arm's length principle at the time of the transaction
D. Marketing activities undertaken by enterprises not owning trademarks or tradenames
Chapter VII. Special Considerations for Intra-Group Services
A. Introduction
B. Main issues
C. Some examples of intra-group services
Chapter VIII. Cost Contribution Arrangements
A. Introduction
B. Concept of a CCA
C. Applying the arm's length principle
D. Tax consequences if a CCA is not arm’s length
E. CCA entry, withdrawal, or termination
F. Recommendations for structuring and documenting CCAs
APPENDIX: Recommendation of the OECD Council
ANNEXES
-Guidelines for Monitoring Procedures on the OECD Transfer Pricing Guidelines and the Involvement of the Business Community
-Examples to Illustrate the Transfer Pricing Guidelines
-Application of the Residual Profit Split Method
-Intangible Property and Uncertain Valuation
-Guidelines for Conducting Advance Pricing Arrangements Under The Mutual Agreement Procedure ("MAP APAs")

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