IFA: Practical Experience with the OECD Transfer Pricing Guidelines
Practical Experience with the OECD Transfer Pricing Guidelines
Erschienen am 5. Januar 2016
68 Seiten
978-90-411-8705-5 (ISBN)
Beschreibung
The 1998 seminar considered whether the OECD Guidelines had started to influence tax legislation or the practice of Revenue authorities. The seminar reviewed recent developments in transfer pricing legislation throughout the world. It considered the results of a questionnaire to multinational groups in the Association, and the views of panel members and other participants.
Weitere Details
Weitere Ausgaben
Inhalt
- Cover
- Title Page
- Copyright Page
- Table of Contents
- Outline of the Seminar
- Chair's Introduction
- Recent Developments in Legislation Internationally
- Transfer Pricing Methods
- The Arm's Length Range
- Documentation
- Burden of Proof - Penalties
- Secret Comparables
- Overview of Developments in Particular Countries
- Denmark introduced documentation requirements recently
- Poland closely follows the OECD
- Questionnaire of Multinational IFA Members
- OECD Transfer Pricing Guidelines - Practical Experience
- Background
- Purpose of Seminar
- Development of Local Laws and Regulations in the Transfer Pricing Area
- Documentation Requirements
- Closing Remarks
- OECD Transfer Pricing Guidelines - A Business Perspective
- 1. General Aspects
- 1.2 OECD Guidelines and their impact outside the OECD member states
- 2. Specific Examples On Improvements Made
- 2.1 Corporate Overheads and Charges
- 2.2 Cost Contribution Arrangements for Research and Development
- 2.3 Intangible property
- trademark royalties
- 3. Summing-up
- The Perspective of Tax Administrations and the OECD
- The US Perspective
- Panel Discussion
- 1. Monitoring
- 2. Advance Pricing Agreements
- 3. Should We Prefer a Strict Order or Best Method Rule?
- 4. The Distinction Between Dispute Settling Methods and Pricing Methods
- 5. Burden of Proof
- 6. Penalties
- 7. Secret Comparables
- 8. Experience of Non-OECD Member States
- 9. Concluding Remarks
- Closing Address
- What's New in OECD?
- Global Trading
- Electronic Commerce
- Back Cover
