Oecd Transfer Pricing Guidelines For Multinational Enterprises And Tax Administration

In a global economy where multinational enterprises (MNEs) play a prominent role, governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdiction and that the tax base reported by MNEs in their country reflects the economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation.

This consolidated version of the OECD Transfer Pricing Guidelines includes the revised guidance on safe harbours adopted in 2013, as well as the recent amendments made by the Reports on Actions 8-10 and 13 of the BEPS Actions Plan and conforming changes to Chapter IX.

The OECD Transfer Pricing Guidelines provide guidance on the application of the “arm’s length principle”, which is the international consensus on transfer pricing, the valuation, for tax purposes, of cross-border transactions between associated enterprises.

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations provides guidance on the valuation for tax purposes of cross-border transactions between associated enterprises.

The increase in global trade and foreign direct investment has seen a large rise in companies operating across national borders. The growth of these multinational companies (MNCs) has been closely followed by the issue of inter-company transfer prices being used to reduce taxable profits. Today, transfer pricing is one of the most important issues facing MNCs as they attempt to fairly distribute their profits amongst each company in the group while dealing with tax authorities who are implementing transfer pricing regulations and strengthening enforcement in order to prevent a loss of revenue. The result of which is that transfer pricing controversies have become a major tax issue for companies. This reference booklet, in addition to containing the OECD’s Transfer Pricing Guidelines, provides an excellent overview of transfer pricing rules and regulations in 35 countries and is a handy guide for those actively working in the field of transfer pricing.--Publisher's description.

A contributed volume, based on the new transfer pricing Treasury regulations (Section 482), by international tax and accounting experts with extensive experience in this area. International corporations dealing with imported or exported products from their subsidiaries are affected by this new rule and those that do not comply will face strict penalties which can be financially damaging. Analyzes numerous aspects of transfer pricing including cost sharing, valuation of intangibles and priority regulations. The final section helps the taxpayer prepare for audits or litigation.

The 2001 edition of Transfer Pricing Guidelines was substantially revised in July 2010. See the current edition. This compact version of Transfer Pricing Guidelines provides the complete and current text of the OECD pricing guidelines accepted by ...