Due to the recent financial and economic crisis, global corporate losses have increased significantly. Numbers at stake are vast, with loss carry-forwards as high as 25% of GDP in some countries. Though most of these claims are justified, some corporations find loop-holes and use ‘aggressive tax planning’ to avoid taxes in ways that are not within the spirit of the law.
On 9 September, the OECD released for public comment a proposed revision of Chapters I-III of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. This follows from the release in May 2006 of a discussion draft on comparability issues and in January 2008 of a discussion draft on transactional profit methods, and from discussions with commentators during a two-day consultation that was held in November 2008.
On 17-18 November 2008, the OECD held a consultation with business commentators on comparability and profit methods for transfer pricing purposes. The consultation followed the release of two discussion drafts on comparability (May 2006) and transactional profit methods (January 2008) under the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, both of which attracted very detailed responses from the business community.
A consultation will be held on 17 and 18 November 2008 with the organisations that provided written comments on the May 2006 discussion draft on comparability and the January 2008 discussion draft on transactional profit methods. The discussion drafts related to the OECD’s Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.
On 25 January 2008, the OECD released an invitation to comment on a series of draft issues notes in relation to transactional profit methods (i.e., the transactional profit split and the transactional net margin methods).
The OECD is issuing an invitation to comment on a series of issues notes that was drafted by the Committee on Fiscal Affairs' Working Party No. 6, building on experience acquired by countries in applying transactional profit methods since the adoption of the Transfer Pricing Guidelines in 1995 and on comments received from the business community.
The OECD releases an invitation to comment on a series of draft issues notes on comparability that was developed by the Committee on Fiscal Affairs Working Party No. 6, building on experience acquired by countries since the adoption of the Transfer Pricing Guidelines in 1995 and on comments received from the business community in response to an open questionnaire released in 2003.
The OECD is now issuing an open invitation to contribute on a number of issues in relation to transactional profit methods. As part of its procedures for monitoring the implementation of the 1995 Transfer Pricing Guidelines, Working Party No 6 of the OECD Committee on Fiscal Affairs has selected the application of transactional profit methods as one of two areas to be considered in priority.
On 10 May 2006, the OECD released a series of draft issues notes on comparability that was developed by the Committee on Fiscal Affairs' Working Party No. 6, building on experience acquired by countries since the adoption of the Transfer Pricing Guidelines in 1995 and on comments received from the business community in response to an open questionnaire release in 2003.
On 27 February 2006 the OECD released an open invitation to comment on a number of issues in relation to transactional profit methods described in the OECD's Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. Numerous contributions have now been received and will be carefully examined by Working Party No. 6 on the Taxation of Multinational Enterprises.
As part of its procedures for monitoring the implementation of the 1995 Transfer Pricing Guidelines, the Working Party No. 6 of the OECD Committee on Fiscal Affairs has selected two areas to be considered in priority. New deadline for comments: 5 September 2003.
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