It emerged last week that Greece has brought its transfer pricing documentation rules into line with the Organisation for Economic Cooperation and Development's (OECD) guidelines in this area.
The OECD transfer pricing guidelines were first issued in 1979. They maintain the arm's length principle of treating related enterprises within a multinational group, and affirm traditional transaction methods as the preferred way of implementing the principle.
In its Transfer Pricing Country Profile of Greece, compiled in January 2007, the OECD noted that with regard to transfer pricing documentation requirements at that time:
"General rules apply. Greece intends to conform with the Code of Conduct on transfer pricing documentation for associated enterprises in (the) EU."
Commenting on the importance of its guidelines in the area of transfer pricing, the Organisation has stated that:
"Many factors other than transfer pricing influence the profitability of multinationals, but transfer pricing is significant for both tax administrations and taxpayers because it affects the allocation of profits from intra-group transactions between the different tax jurisdictions in which a multinational operates."
A comprehensive report in our Intelligence Report series looking at offshore and onshore corporate structures and their tax implications is available in the Lowtax Library at http://www.lowtaxlibrary.com/asp/subs_reports.asp and a description of the report can be seen at http://www.lowtaxlibrary.com/asp/description_report7.asp
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