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Working Party No. 6 of the Organization for Economic Cooperation and Development (OECD) on May 10 made public 12 draft Issues Notes that discuss comparability issues encountered when applying the transfer pricing methods authorized by the 1995 Transfer Pricing Guidelines. Comparability issues often arise when applying the arm’s length principle to controlled transactions in performing transfer pricing comparability analyses, as required by Article 9 of the Model Tax Convention.
Also in this issue:
· OECD Invites Public Comment on TP Comparability Issues
· Canada Revenue Agency Revisits Transfer Pricing Review Committee
· Belgium Introduces New Transfer Pricing Unit and Announces Documentation Circular
· Argentina Introduces New Reporting Requirements Regarding International Transactions
· Denmark, UK, Invoke Arbitration Convention in Thin Capitalization Dispute
· OECD Proposes to Improve Dispute Resolution: An End in Sight?
· Kenya Issues Transfer Pricing Guidelines
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