Transfer Pricing: OECD Transfer Pricing Rules and Guidelines (Portfolio 6936)
-
This Portfolio describes and interprets the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations of the Organization for Economic Cooperation and Development (OECD), as last revised in 2010.
Description
Practitioners will most often encounter the Guidelines in tax audits and competent authority proceedings where the Guidelines are used to shed light on the transfer pricing regulations of a particular country or to reconcile seemingly contradictory transfer pricing rules of two countries. The OECD Guidelines were heavily influenced by transfer pricing developments in the United States, and the Portfolio draws attention to analogs and potential discrepancies between the Guidelines and the U.S. transfer pricing regulations. The Guidelines are organized into ten chapters with alphabetically lettered subchapters; this Portfolio discusses the chapters in order for ease of reference.
Table of Contents
I. Introduction
II. Chapter I of the Guidelines: The Arm’s Length Principle
III. Transfer Pricing Methods
IV. Comparability Analysis
V. Administrative Approaches to Avoiding and Resolving Transfer Pricing Disputes
VI. Documentation
VII. Special Considerations for Intangible Property
VIII. Special Considerations for Intra-Group Services
IX. Cost Contribution Arrangements
X. Transfer Pricing Aspects of Business Restructurings
XI. Transfer Pricing Guidance on Financial Transactions
Partner
Covington & Burling LLP
Executive Director - National Tax
Ernst & Young LLP
Partner
Mayer Brown LLP