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  1. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations
  2. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2010
  3. Chapters
  4. Preface
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OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2010
Chapters
Foreword
Preface
Glossary
The Arm's Length Principle
Transfer Pricing Methods
Comparability Analysis
Administrative Approaches to Avoiding and Resolving Transfer Pricing Disputes
Documentation
Special Considerations for Intangible Property
Special Considerations for Intra-Group Services
Cost Contribution Arrangements
Transfer Pricing Aspects of Business Restructurings
Annex to the OECD Transfer Pricing Guidelines
Annex I to Chapter II. Sensitivity of Gross and Net Profit Indicators
Annex II to Chapter II. Example to Illustrate the Application of the Residual Profit Split Method
Annex III to Chapter II. Illustration of Different Measures of Profits When Applying a Transactional Profit Split Method
Annex to Chapter III. Example of a Working Capital Adjustment
Annex to Chapter IV. Guidelines for Conducting Advance Pricing Arrangements under the Mutual Agreement Procedure ("MAP APAs")
Annex to Chapter VI. Examples to Illustrate the Guidance on Intangible Property and Highly Uncertain Valuation
Appendix. Recommendation of the Council on the Determination of Transfer Pricing between Associated Enterprises [C(95)126/Final]
OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2009

Preface

Content Provider OECD iLibrary
Organization OECD
Abstract The role of multinational enterprises (MNEs) in world trade has increased dramatically over the last 20 years. This in part reflects the increased integration of national economies and technological progress, particularly in the area of communications. The growth of MNEs presents increasingly complex taxation issues for both tax administrations and the MNEs themselves since separate country rules for the taxation of MNEs cannot be viewed in isolation but must be addressed in a broad international context.
Page Count 6
Starting Page 17
Ending Page 22
Language English
Publisher OECD Publishing
Publisher Date 2010-08-16
Access Restriction Open
Subject Keyword Finance and Investment Taxation Industry and Services Trade
Content Type Text
Resource Type Chapter
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