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FEDERAL PUBLICATIONS INC. |
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OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2009 |
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| Format | Softcover | |
| Catalogue No. | 232009111P | |
| Pages | 243 | |
| Language | English; Aussi disponible en français | |
| Price | $99.00 | |
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| Published by the Organisation for Economic Co-operation and Development, 2009. Description: |
| OECD Transfer Pricing Guidelines for Multinational
Enterprises and Tax Administrations provides guidance on the application of
the "arm's length principle" for valuation for tax purposes of cross-border
transactions between associated enterprises. 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 that may result from a
dispute between two countries on the determination of the arm's length
remuneration for their cross-border transactions with associated
enterprises. The OECD Transfer Pricing Guidelines clarifies these issues and were originally approved by the OECD Council in 1995. In this 2009 edition, some amendments have been made to Chapter IV, primarily to reflect the adoption, in the 2008 update of the Model Tax Convention, of a new paragraph 5 of Article 25 dealing with arbitration, and of changes to the Commentary on Article 25 on mutual agreement procedures to resolve cross-border tax disputes. References to good practices identified in the online Manual for Effective Mutual Agreement Procedures (www.oecd.org/ctp/memap) have also been included and the foreword and preface have been updated. Please note: The 1999 Binder edition is out of print (cat # 231999671P). The OECD is currently undertaking an important further update to the TPG, focusing on comparability issues and on the application of transactional profit methods. If adopted, these changes are expected to be published in 2010. |
| Price and availability subject to change.
Shipping and applicable taxes extra. Questions about this product? Please e-mail us. This page last modified: October 19, 2009 |
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