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  • 11-February-2020

    English

    Transfer Pricing Guidance on Financial Transactions: Inclusive Framework on BEPS: Actions 4, 8-10

    This report contains transfer pricing guidance on financial transactions, developed as part of Actions 4 and 8-10 of the OECD/G20 Inclusive Framework on BEPS Action Plan.

  • 28-August-2018

    English, PDF, 601kb

    Singapore - Transfer Pricing Country Profile

    Singapore - Transfer Pricing Country Profile

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  • 21-June-2018

    English

    Guidance for Tax Administrations on the Application of the Approach to Hard-to-Value Intangibles - BEPS Action 8

    The new guidance is aimed at reaching a common understanding and practice among tax administrations on how to apply adjustments resulting from the application of the approach to hard-to-value intangibles (HTVI). This guidance should improve consistency and reduce the risk of economic double taxation by providing the principles that should underlie the application of the HTVI approach.

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  • 21-June-2018

    English

    Revised Guidance on the Application of the Transactional Profit Split Method - BEPS Action 10

    This report contains revised guidance on the profit split method, developed as part of Action 10 of the BEPS Action Plan. This guidance will be incorporated into the OECD Transfer Pricing Guidelines, replacing the previous text on the transactional profit split method in Chapter II.

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  • 22-March-2018

    English

    Additional Guidance on the Attribution of Profits to a Permanent Establishment under BEPS Action 7

    This report contains additional guidance on the attribution of profits to permanent establishments resulting from the changes in the Report on BEPS Action 7 to Article 5 of the OECD Model Tax Convention.

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  • 22-March-2018

    English

    BEPS Actions

    Developed in the context of the OECD/G20 BEPS Project, the 15 BEPS actions equip governments with domestic and international instruments to address tax avoidance, ensuring that profits are taxed where economic activities generating the profits are performed and where value is created. Under the inclusive framework, over 100 countries and jurisdictions are now collaborating to implement the BEPS measures and tackle BEPS.

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  • 22-June-2017

    English

    Addressing Difficulties in Accessing Comparables Data for Transfer Pricing Analyses

    This Toolkit responds to a request by the Development Working Group of the G20, and addresses an area of tax called "transfer pricing," which refers to the prices corporations use when they transact between members of the same group. How these prices are set has significant relevance for the amount of tax an individual government can collect from a multinational enterprise.

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  • 23-May-2017

    English

    OECD releases a discussion draft on the implementation guidance on hard-to-value intangibles

    Public comments are invited on a discussion draft which provides guidance on the implementation of the approach to pricing transfers of hard-to-value intangibles described in Chapter VI of the Transfer Pricing Guidelines.

  • 5-December-2016

    English

    OECD releases further BEPS guidance on Country-by-Country reporting and country-specific information on implementation

    The Inclusive Framework on BEPS has released two new documents to support the global implementation of Country-by-Country (CbC) reporting (BEPS Action 13).

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  • 5-October-2015

    English

    Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 - 2015 Final Reports

    The report contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation. The revised guidance focuses on the following key areas: transfer pricing issues relating to transactions involving intangibles; contractual arrangements, including the contractual allocation of risks and corresponding profits, which are not supported by the activities actually carried out; the level of return to funding provided by a capital-rich MNE group member, where that return does not correspond to the level of activity undertaken by the funding company; and other high-risk areas. The report also sets out follow-up work to be carried out on the transactional profit split method which will lead to detailed guidance on the ways in which this method can appropriately be applied to further align transfer pricing outcomes with value creation.
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