Results 91 to 100 of about 372 (131)

Proposed Revision of OECD Transfer Pricing Guidelines: The Importance of Facts and Circumstances

International Transfer Pricing Journal, 2009
On 9 September 2009, the OECD released for public comments a proposed revision of the Chapters I through III of the OECD Transfer Pricing Guidelines. This article provides a summary of the most important proposed changes, the relevance for practice and alternative considerations in a number of areas.
exaly   +2 more sources

The UN Practical Manual on Transfer Pricing for Developing Countries: Should It Depart from the OECD Transfer Pricing Guidelines?

International Transfer Pricing Journal, 2012
This article will address the issue of transfer pricing regulations in developing countries and, more particularly, the development of the United Nations Transfer Pricing Manual for use by developing countries. The main focus is on whether the UN Manual should depart from the OECD Transfer Pricing Guidelines.
exaly   +2 more sources

OECD Proposed Revision of Chapters I-III of the OECD Transfer Pricing Guidelines: Business Comments on Selected Issues

International Transfer Pricing Journal, 2010
On 9 September 2009, the OECD released for public comment the Proposed Revision of Chaps. I-III of the OECD Transfer Pricing Guidelines. The latest input from private stakeholders, which has been sought throughout the different phases of this project, is currently being analysed by the OECD, which has the intention to finalize the project by the end of
M.O. Lucas Mas, G. Cottani
exaly   +2 more sources

The Substance Requirement in the OECD Transfer Pricing Guidelines: What Is the Substance of the Substance Requirement?

International Transfer Pricing Journal, 2014
The author investigates the content of the substance requirement in the OECD Guidelines. When relevant, it is compared to the substance requirement in the US transfer pricing regulations and other sources of international tax law, such as the OECD Model Tax Convention.
exaly   +2 more sources

Zambia’s First Transfer Pricing Case: An Opportunity Lost to Use the Updated OECD and UN Transfer Pricing Guidelines for Developing Countries

Bulletin for International Taxation, 2019
The first Zambian transfer pricing court case was decided on 28 March 2019 by the Income Tax Appeals Tribunal in Lusaka. The author, in this article, considers the reasoning and the findings of the case and makes some observations regarding its implications.
exaly   +2 more sources

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022
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OECD Transfer Pricing Guidelines and International Tax Law

2023
Abstract This chapter evaluates the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration, which is the main international standard regarding transfer pricing. In the international tax system, permanent establishments belonging to multinational groups are usually taxed as separate entities in the ...
Yuri Matsubara, Clémence Garcia
openaire   +1 more source

The Use of Paragraphs 1.119 to 1.128 of the 2017 OECD Transfer Pricing Guidelines for the Application of Transfer Pricing Rules

Intertax, 2020
This article aims to analyse the paragraphs 1.119 to 1.128 of the 2017 OECD Transfer Pricing Guidelines and their relation to the comparability analysis, sham transactions and domestic anti-avoidance rules. For this purpose, the authors discuss the nature of the transfer pricing rules, the limits of the OECD transfer pricing guidelines to the ...
Paul Nina Nina, Luis Durán Rojo
openaire   +1 more source

The OECD Discussion Draft on the Transfer of Intangibles (Revision of Chapter VI of the OECD Transfer Pricing Guidelines) – Detailed Comments

Intertax, 2013
  On 6 June 2012, the Organisation for Economic Co-operation and Development (OECD) released a discussion draft on the Proposed Revision of Chapter VI of the OECD Transfer Pricing Guidelines (TPG) and Related Provisions. Intertax publishes the full text of the discussion draft together with the comments submitted by members of Baker & McKenzie ...
Caroline Silberztein, Mary C. Bennett, Gregg D. Lemein   +2 more
openaire   +1 more source

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2017
exaly   +2 more sources