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OECD Consults On Transfer Pricing

by Ulrika Lomas, for LawAndTax-News.com, Brussels

17 May 2006

The Organisation for Economic Cooperation and Development (OECD) last week announced that it is seeking comment on comparability issues affecting transfer pricing methods.

The paper, entitled 'Comparability: Public Invitation to Comment on a Series of Draft Issues Notes' was published last Wednesday.

In a statement, the Organisation explained that:

"As part of its procedures for monitoring the implementation of the 1995 Transfer Pricing Guidelines, Working Party No. 6 of the OECD Committee on Fiscal Affairs selected two areas to be considered in priority:

• Comparability issues encountered when applying the transfer pricing methods authorised by the 1995 TP Guidelines and
• The application of transactional profit methods (i.e., the transactional profit split methods and the transactional net margin method)."

"While recognising that the two projects are intrinsically linked, the Working Party started with a review of comparability issues in general. An open invitation to comment on comparability issues was released in 2003. Detailed contributions were received from the business community, most of which are available on the OECD Internet site."

"Comments are now invited on the attached series of draft Issues notes that was developed by Working Party No. 6, building on experience acquired by countries since the adoption of the Transfer Pricing Guidelines in 1995 and on comments received from the business community in response to the 2003 invitation. A separate invitation to comment on issues related to profit methods was released on 28 February 2006."

Comment on the matter is invited until November 30.

The full text of the OECD consultation on comparability issues affecting transfer pricing methods can be found in the Tax News Resources section.

 

 






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