Transfer pricing guidelines for multinational enterprises and tax administrations.

Format:

Book

Contributor:

Organisation for Economic Co-operation and Development, Content Provider.

Language:

English

Subjects (All):

Transfer pricing--Taxation--Law and legislation.

Transfer pricing.

International business enterprises--Taxation--Law and legislation.

International business enterprises.

Physical Description:

1 online resource (262 p.)

Place of Publication:

Paris, France : OECD Publications Services, [2001]

Language Note:

English

Summary:

The OECD Transfer Pricing Guidelines were published in 1995, with updates every year up to 1999. This travel version contains all that material but in a compact format that makes it easy to take out of the office.

Contents:

""CONTENTS""; ""Preface""; ""Glossary G""; ""Chapter 1. The Arm's Length Principle ""; ""A. Introduction""; ""B. Statement of the arm's length principle""; ""C. Guidance for applying the arm's length principle I""; ""Chapter II. Traditional Transaction Methods ""; ""A. Introduction""; ""B. Relationship to Article 9""; ""C. Types of traditional transaction methods""; ""D. Relationship to other methods""; ""Chapter III. Other Methods ""; ""A. Introduction ""; ""B. Transactional profit methods""; ""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 determining transfer pricing ""

""D. General recommendations on documentation""""Chapter VI. Special Considerations for Intangible Property ""; ""A. Introduction""; ""B. Commercial intangibles""; ""C. Applying the arm's length principle""; ""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""; ""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"")""

Notes:

Description based upon print version of record.

Description based on print version record.

ISBN:

1-280-02990-0

9786610029907

92-64-19221-2

OCLC:

700684106