Date |
Document |
Institution |
MCC |
Or Lan |
§ / Pages |
Summary |
04/09/58 |
FC/WP7(58)1 |
WP7 - FC - OEEC |
UK, NL |
En |
- |
First report containing a general discussion of the topic, a
Draft Article and its Commentary |
10/11/58 |
FC/WP7(58)2 |
WP7 - FC - OEEC |
UK, NL |
En |
- |
The WP7 provides an explanation for critical words in the text
and suggests possible amendments to be discussed |
09/03/59 |
FC/WP7(59)1 |
WP7 - FC - OEEC |
UK, NL |
En |
- |
Report containing clarifications to the previous ones, a Draft
Article and its Commentary |
18/01/60 |
FC/WP7(60)1 |
WP7 - FC - OEEC |
UK, NL |
En |
- |
Revised report with a Draft Article and its Commentary |
20/02/60 |
FC/M(60)1 |
FC - OEEC |
- |
Fr |
II/ 3 |
Comments and amendments to the Article and its Commmentry in
report FC/WP7(60)1 |
14/03/60 |
FC(60)1 |
FC - OEEC |
- |
Fr & En |
- |
Text of the Article with its Commenary as adopted by the
Committee |
24/03/60 |
TFD/FC/87 |
FC - OEEC |
UK |
- |
- |
Amendment already included in the text of document FC/M(60)1 |
25/05/60 |
FC(60)2 |
FC - OEEC |
- |
Fr |
- |
Text of the Article as drafted by the Drafting Group |
21/07/60 |
C(60)157 (Final) |
Council - OEEC |
- |
- |
- |
Final text of the Article |
26/01/62 |
TFD/FC/137 (1st Revision) |
Drafting Group - FC - OECD |
- |
Fr & En |
§/18-19 |
Article text revised |
21/02/63 |
FC(63)2 |
FC - OECD |
- |
En & Fr |
§ / 13 |
Latest draft model convention. |
14/11/66 |
TFD/FC/202 |
FC - OECD |
- |
En & Fr |
A / 2 |
Questions relating to the 1963 Draft Convention left for
future discussion by the FC: paragraph of 1963 Report in which question was
raised: 53; Working Party in charge: WP7 |
06/02/67 |
TFD/FC/208 |
FC - OECD |
- |
En |
§ / 27-28 |
Analysis of conformity with or deviation from 1963 Draft OECD
Model in tax treaties signed between July 1963 and July 1966. |
27/02/67 |
TFD/FC/208 (ANNEX) |
FC - OECD |
- |
En |
§ / 6 |
Analysis of conformity with or deviation from 1963 Draft OECD
Model in tax treaties protocols signed between July 1963 and July 1966. |
14/04/67 |
TFD/FC/214 |
FC - OECD |
- |
En |
§ / 7-8 |
Analysis of deviations from the 1963 Draft OECD Convention in
tax treaties signed between 1 July 1963 and 1 Jan 1967. |
17/04/67 |
TFD/FC/214 (ANNEX) |
FC - OECD |
- |
En |
§ / 2 |
Analysis of deviations from the 1963 Draft OECD Convention in
tax treaties protocols signed between 1 July 1963 and 31 July1966. |
09/05/67 |
TFD/FC/216 |
FC - OECD |
BE |
En & Fr |
§ / 13 |
Observations of member countries about difficulties in the
1963 OECD Draft Convention on income and capital. This document supercedes
TFD/FC/209 of 28th February, 1967. |
21/07/67 |
TFD/FC/218 |
FC - OECD |
BE |
En & Fr |
§ / 28 |
Consolidated list of comments made on the OECD Draft
Convention, on which future action may be required. Supercedes TFD/FC/202 dt
14/11/66, TFD/FC/209 dt 28/02/67, TFD/FC/210 dt 13/03/67, and TFD/FC/216 dt
09/05/67. |
25/07/67 |
TFD/FC/219 |
FC - OECD |
UK NL |
En & Fr |
§ / 7 |
Existing WP7 comprising UK & NL working on extended
mandate for Article 7 for allocation of profits to PEs & Aes, including
allocation of profits from the continental shelf. |
16/09/67 |
TFD/FC/222 |
FC - OECD |
- |
En |
§ / 36-37 |
Analysis of conformity with or deviation from 1963 Draft OECD
Model in tax treaties signed between 01/07/63 and 01/01/67. |
16/09/67 |
TFD/FC/222 |
FC - OECD |
- |
En |
§ / 111 |
Analysis of conformity with or deviation from 1963 Draft OECD
Model in protocols signed between 01/07/63 and 01/01/67. |
06/10/67 |
TFD/FC/226 |
FC - OECD |
- |
En |
- |
Notes on the discussion about the allocation of profits to a
PE and AEs at the 27th Session of the Fiscal Committee held from 19/09/67 to
22/09/67. |
26/02/68 |
TFD/FC/229 |
FC - OECD |
- |
En |
B / 5-9 |
Notes from the 28th session of the FC - discussions and
debates on the allocation of profits according to the ALP. |
16/05/69 |
DAF/FC/69.8 |
FC - OECD |
- |
En |
73-78/52-55 |
Preliminary analysis of devaitions from the 1963 Draft in tax
treaties signed between 01/07/63 and 01/01/69 - supercedes TFD/FC/222 of
16/09/67. |
16/05/69 |
DAF/FC/69.8 |
FC - OECD |
- |
En |
214/166 |
Preliminary analysis of devaitions from the 1963 Draft in
protocols signed between 01/07/63 and 01/01/69 - supercedes TFD/FC/222 of
16/09/67. |
04/06/70 |
FC(70)1 |
FC - OECD |
- |
En |
73-78 / 43-45 |
Analysis of deviations of actual tax treaties concluded
amongst member countries, between 01/07/63 and 01/01/69 from the 1963 OECD
Draft. |
04/06/70 |
FC(70)1 |
FC - OECD |
- |
En |
214 / 129 |
Analysis of deviations of protocols concluded amongst member
countries, between 01/07/63 and 01/01/69 from the 1963 OECD Draft. |
19/06/70 |
FC/WP7(70)1 |
WP7 - FC - OECD |
UK NL |
En |
- |
Study of 2 factors: what are the relevant factors in
determining ALP; whether corresponding adjustments should be made? |
13/10/70 |
DAF/FC/70.11 |
FC - OECD |
- |
En |
B (11-15, 18) / 4-5 |
Notes on the discussion about the second report of WP7 - price
adjustment between parent and daughter company. |
12/11/70 |
FC/WP7(70)2 |
WP7 - FC - OECD |
UK NL |
En |
1-14 / 1-6 |
Proposals for provision and commentary on corresponding
adjustments; examination of timing issues for corresponding adjustments. |
16/12/70 |
DAF/FC/7Q.14 |
FC - OECD |
- |
En |
B . 4-5 |
Proposals for the amendment of Article 9 and commentaries
thereon for providing for corresponding adjustments, which were agreed to by
the Fiscal Committee |
11/02/71 |
DAF/FC/71.4 |
FC - OECD |
- |
En & Fr |
- |
Modifications to the summary record and notes on the 37th
session of the FC contained in [FC/M(70)4 of 10/12/70, DAF/FC/70.14 dt
16/12/70, and FC(71)1 dt 14/01/71]. |
12/03/71 |
FC/WP7(71)1 |
WP7 - FC - OECD |
UK NL |
En |
- |
Amendments to Article 9 and the Commentaries thereon are
submitted to the Committee for formal approval at its 39th Session. |
17/06/71 |
CFA/WP1(71)3 |
WP1 - CFA - OECD |
- |
En & Fr |
§ / 4-5 |
Latest version of Article. |
23/09/71 |
DAF/CFA/WP1/71.5 |
WP1 - CFA - OECD |
- |
En |
VII / 2 |
WG7 invites notes from countries which have practical
experience in the field of applying the ALP. |
10/11/71 |
CFA(71)10 |
CFA - OECD |
- |
Fr & En |
§ / 5-6, 24-26 |
Revised text of Article and Commentary as unanimously approved
by the Fiscal Committee or by Working Party N° 1. |
07/01/72 |
CFA(71)10 (Corr) |
CFA - OECD |
- |
En & Fr |
C / 6 |
Corrigendum to the revised commentaries to Article 9 as
contained in CFA(71)10 dt 10/11/71. |
10/02/72 |
CFA(71)10 (1st Revision) |
CFA - OECD |
- |
En & Fr |
§ / 6, 22-24 |
Revised text of Article and Commentary as adopted by WP1
during its 2nd session. Contents of CFA(71)10 dt 10/11/71 revised. |
21/02/72 |
CFA/WP1(72)4 |
WG7 - WP1 - CFA - OECD |
UK NL |
- |
55-59 / 19-20 |
4th Report of WG7: list of proposals on Article 9. |
15/06/72 |
CFA(72)7 |
CFA - OECD |
- |
En |
21-22 / 6-7 |
Paper on taxation aspects of the activities of international
companies. |
28/07/72 |
DAF/CFA/WP1/72.9 |
WP1 - CFA - OECD |
- |
Fr |
II / 15-16 |
Discussion of the 4th report of WG7 [contained in CFA/WP1(72)4
of 21/02/72]. |
11/12/72 |
DAF/CFA/WP1/72.11 |
WP1 - CFA - OECD |
- |
En |
II / 2 |
WP1 concluded its discussion of the 4th report of Working
Group No. 7 [contained in CFA/WP1(72)4 dt 21/02/72] |
15/12/72 |
DAF/CFA/WP1/72.12 |
WP1 - CFA - OECD |
- |
En |
I / 3 |
Summary of discussions during the 6th Meeting of the CFA:
Discussion of the 4th report of WG7 [CFA/WP1(72)4 dt 21/02/72]. |
26/02/73 |
CFA/WP6(73)1 |
WP6 - CFA - OECD |
|
Fr |
6 / 2 |
The problem of “arm's-length” prices of Multinational
Enterprises |
12/04/73 |
CFA/WP1(73)3 |
WP1/WG7 - CFA - OECD |
UK,NL |
En |
- |
Determination Arm´s Length Prices; Agreement has not been
reached between tax administration on the Need of Universal Guidelines |
16/04/73 |
DLF/CFA/W P6/73.1 |
WP6 - CFA - OECD |
- |
En |
§ / P6 |
Drafted Report on The problem of “arm's-length” prices of
Multinational Enterprises |
21/05/73 |
CFA(73) 4 |
WP6 - CFA - OECD |
- |
En |
§ / P6 |
Taxation of Multinational Enterprises (The problem of
“arm's-length” prices of Multinational Enterprises |
29/05/73 |
CFA(75)5 |
WP6 - CFA - OECD |
- |
En |
- |
The Working Party approved report deals with loans and
interest payments between affiliated companies. |
05/06/73 |
DAF/CFA/WP1(73)8 |
WP1 - CFA - OECD |
- |
En |
- |
Determination of the arm’s length prices [Discussion of the
1st Report of Working Group N° 7 (CFA/WP1(73)3 of 12th April 1973)] |
05/06/73 |
DAF/CFA/WP1(73)8 |
WP1 - CFA - OECD |
- |
En |
- |
Discussion of the 1st Report of Working Group No 7
(CFA/WP1(73)3 of 12th April 1973)] |
26/06/73 |
CFA/M(73)2 |
CFA - OECD |
- |
En |
- |
The Working Party examined the report [CFA/WP1(73)3 of 12th
April, 1973] and decided that It would be for the Plenary Committee to decide
whether any further studies should be made in this field and, if so, by what
bodies of the Committee. |
15/09/73 |
CFA/VP1(73)9 |
WG30 - WP1 - CFA - OECD |
- |
Fr |
15 / 5 |
Can partnerships as such enjoy the benefits of Article 9? |
12/11/73 |
DAF/CFA/WP6/73.4 |
WP6 - CFA - OECD |
- |
En |
- |
Overview of what is available in the published literature, or
in O.E.C.D. reports from Working Party No.1, on the question of international
transfer pricing policies. |
22/11/73 |
DAF/CFA/WP6/73.4 (Corr) |
WP6 - CFA - OECD |
- |
En & Fr |
- |
The diagram referred to
in paragraph 6 of the Secretariat's Note DAF/CFA/WP6/73.4 of the 12th
November, 1973. |
04/12/73 |
DAF/CFA/WP6/73.6 |
WP6 - CFA - OECD |
- |
En |
5 / 3 |
The working party decided to study further the indirect and
direct transfer pricing methods mentioned on the Secretariat note DAF/CFA/WP6/73.4 (of 12th
November 1973) |
01/02/74 |
DAF/CFA/74.1 |
WP6 - CFA - OECD |
- |
En |
- |
Summary of the replies
of the questionnaire DAF/CFA/2926 concerning Transfer Prices |
03/02/74 |
DAF/CFA/75.2 |
WP6 - CFA - OECD |
- |
En! |
- |
Note has been prepared by the Secretariat and points out major problems as regards
transfer prices for rights and services between affiliated companies. |
21/05/74 |
CFA(74)6 |
WP6 - CFA - OECD |
- |
En |
9-28 / 4-9 |
Transfer Pricing issues of Multinational Enterprises, Problem,
Possible Solution, Guidelines for a good Multinational |
21/05/74 |
CFA(74)6rev1 |
WP6 - CFA - OECD |
- |
En |
9-28 / 4-9 |
Committee on Fiscal Affairs at its seventh session adopted the
first revision of the document CFA(74)6 |
10/06/74 |
CFA(74)6 (Corr) |
WP6 - CFA - OECD |
- |
Fr & En |
- |
Corrections to the document CFA(74)6 |
26/06/74 |
DAF/CFA/74.5 |
CFA - OECD |
- |
- |
- |
United States Opinion, recommendations and future work
concerning Transfer Pricing |
26/06/74 |
DAF/CFA/74.6 |
WP6 - CFA - OECD |
- |
- |
- |
The document exposes the U.S. Tax Treatment of Loans as a
Problem in Transfer Pricing |
10/07/74 |
DAF/CFA/74.7 |
CFA - OECD |
- |
En! |
- |
Transfer Pricing and Treatment of loan interest of the
conclusions of the first meeting [DAF/CFA/74.4 of 20th May 1974 |
12/09/74 |
DAF/CFA/74.13 |
WP6 - CFA - OECD |
UK |
En! |
- |
The document contains the (Arm´s length) taxation of royalties
and similar payments between affiliated companies operating internationally. |
12/09/74 |
DAF/CFA/74.12 |
WP6 - CFA - OECD |
UK |
En! |
- |
The document contains the (Arm´s length) taxation of interest
of loans between affiliated companies operating internationally. |
20/09/74 |
DAF/CFA/74.17 |
WP6 - CFA - OECD |
CH |
En! |
- |
The document contains a note by Switzerland concerning the
(Arm´s length) Allocation of interest between related enterprises |
15/10/74 |
DAF/CFA/74.19 |
WP6 - CFA - OECD |
- |
En |
- |
The document contains a note for the tax treatment of
intra-company loans and interest thereon to be used at the meeting on 16th
October, 1974. |
31/10/74 |
DAF/CFA/74.21 |
WP6 - CFA - OECD |
- |
En |
- |
The draft of a report from the Working Group on Transfer
Prices (loans) between related enterprises |
13/11/74 |
CFA(74)15 |
CFA - OECD |
- |
En |
10b / 3 |
The document contains proposals concerning future work on tax
evasion and the possibility to solve it through transfer prices |
20/12/74 |
DAF/CFA/74.26 |
WP6 - CFA - OECD |
- |
En |
- |
Draft report of The first report dealing with loans and
interest payments between affiliated companies |
20/01/75 |
DAF/CFA/75.1 |
CFA - OECD |
DE |
En! |
- |
The German practice of taxation of royalties and similar
payments between affiliated companies |
12/02/75 |
DAF/CFA/75.4 |
CFA - OECD |
US |
En! |
- |
Comments and amendments from the United States Delegation on
the draft report concerning the transfer pricing treatment of Loans between
affiliated companies. |
28/02/75 |
DAF/CFA/WP6/ 75.4 |
WP6 - CFA - OECD |
- |
En! |
- |
This report deals with the arms length prices of loans and
interest payments between affiliated companies |
15/04/75 |
DAF/CFA/75.6 |
CFA - OECD |
- |
En! |
- |
The document discusses the transfer or use of intangible
property between affiliated companies |
29/04/75 |
DAF/CFA/75.8 |
CFA - OECD |
- |
En |
- |
The document contains the opinions of the BIAC (Business and
Industry Advisory Committee to OECD) regarding multinational enterprises and
transfer pricing |
16/05/75 |
DAF/CFA/75.10 |
CFA - OECD |
US |
En! |
- |
United States law of Rights and Services between affiliated
companies |
21/05/75 |
CFA/WP1(75)3 |
WG21 - WP1 - CFA - OECD |
US,DK,DE |
En |
27 / 24,25 |
Improper use and abuse
of tax conventions (Profit Shifting) |
10/06/75 |
DAF/CFA/75.14 |
CFA - OECD |
- |
En |
- |
The document contains the opinions of the biac (business and
industry advisory committee to OECD)regarding the oecd report on tax
treatment of interest on loans between affiliated companies [CFA(75)5 of 29th
May, 1975] |
08/07/75 |
CFA/M(75)2 |
CFA - OECD |
- |
En |
4/ 4 |
The Committee adopted the report of Working Party No. 6 on the
tax treatment of interest on loans between affiliated enterprises
CFA(75)5. |
28/07/75 |
DAF/CFA/75.16 |
CFA - OECD |
- |
En! |
- |
The document contains a note by the secretariat on the use of
Intangible property between affiliated enterprises |
01/09/75 |
DAF/CFA/75.17 |
CFA - OECD |
- |
En! |
- |
Questions for consideration by the special working group on
transfer pricing |
19/09/75 |
DAF/CFA/75.20 |
CFA - OECD |
UK |
En! |
- |
Note of the United Kingdom´s delegate concerning the document
DAF/CFA/75.16 |
01/10/75 |
DAF/CFA/75.18 |
CFA - OECD |
- |
En |
8/ 3 |
Problems of Transfer Pricing an analysis of the answers to the
Questionnaire on Tax Avoidance and Evasion DAF/CFA/3931 of 23rd January 1975 |
01/10/75 |
DAF/CFA/75.18 (Corr) |
CFA - OECD |
- |
En |
- |
Amendments to the document DAF/CFA/75.18 tax avoidance and
evasion analysis of the answers to questionnaire |
27/10/75 |
DAF/CFA/75.25 |
WP6 - CFA - OECD |
- |
En! |
- |
The Working Group took decisions concerning Loans, Rights,
Services and Goods between affiliated enterprises |
08/01/76 |
DAF/CFA/75.18 (Corr) |
CFA - OECD |
- |
En & Fr |
- |
Corrections received by the Secretariat to the analysis of the
answers to the questionnaire [DAF/CFA/75.18 of 1st October, 1975]. |
15/01/76 |
DAF/CFA/76.2 |
WP6 - CFA - OECD |
- |
En! |
- |
First draft report on the taxation and use of Intangible
profits between affiliated enterprises. |
26/01/76 |
DAF/CFA/76.3 |
WP6 - CFA - OECD |
- |
En! |
- |
A Note prepared by the Secretariat containing more information
on the practices of multinational groups in the area of servicing
continuation of the Doc.(DAF/CFA/75.17) |
26/01/76 |
CFA/M(77)1 |
CFA - OECD |
- |
En |
3/ 2 |
Decisions taken concerning the 1963 draft double taxation
convention [CFA(76)7 parts I to IV) |
28/01/76 |
DAF/CFA/76.4 |
WP6 - CFA - OECD |
- |
En! |
- |
The list of questions submitted for consideration by the
Working Group to facilitate the discussion of the draft report DAF/CFA/76.2
of 15th January 1976. |
15/02/76 |
DAF/CFA/76.6 |
WP6 - CFA - OECD |
- |
En! |
- |
Countries notes on rights (DAF/CFA/76.2), on services
(DAF/CFA/76.3) and future meetings of the Working Group |
26/03/76 |
DAF/CFA/76.9 |
WP6 - CFA - OECD |
- |
En! |
- |
Re-draft of the document DAF/CFA/76.2 (includes changes of the
meeting held the 10th and 11th of February 1976) |
31/03/76 |
DAF/CFA/76.10 |
WP6 - CFA - OECD |
- |
En! |
- |
Re-draft of the document DAF/CFA/76.3 (includes changes of the meeting held the 11th of February
1976) |
04/05/76 |
DAF/CFA/76.11 |
WP6 - CFA - OECD |
- |
En! |
- |
Working Party Decisions concerning Patents and know How Doc. DAF/CFA/76.9, Services Doc. DAF/CFA/76.10 and Goods |
24/05/76 |
DAF/CFA/76.12 |
CFA - OECD |
- |
En |
7/ 2 |
Payments for Patents and Know How) Subjects for discussion and
preparation for the Committee next session on the 23rd and 24th june 1976 |
03/06/76 |
DAF/CFA/76.14 |
WP6 - CFA - OECD |
- |
En |
- |
Provisional report on the pricing policies for intra-group
transfers of intangible property (patents, know-how) used by related
companies |
16/07/76 |
DAF/CFA/76.14rev1 |
WP6 - CFA - OECD |
- |
En |
- |
1st revision of the 1st report on the pricing policies for
intra-group transfers of intangible property (patents, know-how) used by
related companies |
03/08/76 |
DAF/CFA/76.14rev1 (Ann) |
WP6 - CFA - OECD |
- |
En |
- |
The document contains the Annex referred to in document
DAF/CFA/76.14 (1st Revision) of 15th July, 1976. |
05/11/76 |
DAF/CFA/76.21 |
CFA - OECD |
- |
En & Fr |
§ / p6 |
Discussion of payments in respect of patents and know how
between related and unrelated enterprises, during the meeting of tax
inspector concerning tax avoidance and tax evasion |
05/11/76 |
DAF/CFA/WP1/76.19 |
WP1 - CFA - OECD |
- |
En & Fr |
§ / 46 |
The revised texts of
the Commentaries on the thirty Articles of the 1963 Draft Convention |
08/11/76 |
DAF/CFA/76.25 |
WP6 - CFA - OED |
UK |
En! |
- |
The document contains a UK note concerning transfer prices for
goods between related enterprises |
22/11/76 |
CFA (76)7 PART II |
WP1 - CFA - OECD |
- |
- |
§ / 24 |
Revision on the Articles, Commentaries and Reservations of the
1963 Draft Double Taxation convention |
02/12/76 |
CFA(76)7, Part I |
WP1 - CFA - OECD |
- |
- |
- |
PART 1: An examination of the historical background,
implementation of the 1963 model convention , 1977 model convention,
commentaries and articles, multilateral conventions |
10/12/76 |
CFA(76)7 PART II
(Corr) |
WP1 - CFA - OECD |
- |
- |
- |
The document contains corrections to the texts issued on 22nd
November, 1976 CFA (76)7 PART II |
17/12/76 |
DAF/CFA/76.14rev2 |
WP6 - CFA - OECD |
- |
En |
- |
2nd revision of the document DAF/CFA/76.1 concerning the
pricing policies for intra-group transfers of intangible property (patents,
know-how) used by related companies in multinational groups |
30/12/76 |
CFA(76)7, Part IV |
WP1 - CFA - OECD |
- |
- |
§ / 12 |
Part 4: Reservations on the Articles |
24/01/77 |
DAF/CFA/76.14rev3 |
WP1 - CFA - OECD |
- |
En |
- |
3rd revision of the document DAF/CFA/76.1 concerning the
pricing policies for intra-group transfers of intangible property (patents,
know-how) used by related companies in multinational groups |
01/03/77 |
CFA (76)7part2rev1 |
WP1 - CFA - OECD |
- |
Fr & En |
§ / 24 |
1st revision and final
texts of the articles of the 1977 model double taxation convention adopted by
the committee on fiscal affairs on 18th january 1977 |
04/03/77 |
CFA(76)7 Part III (Corr) |
WP1 - CFA - OECD |
- |
En & Fr |
1 / 1 |
The document contains the amendments and observations made by
Member countries to the Commentaries |
04/03/77 |
CFA(76)7 Part III (Corr) |
WP1 - CFA - OECD |
- |
En & Fr |
2 / 5 |
The document observations made by Member countries to the
Commentary |
07/03/77 |
CFA(76)7part1rev1 |
WP1 - CFA - OECD |
- |
En & Fr |
- |
1st revision and final version of Part I CFA(76)7, Part I |
11/03/77 |
CFA(76)7part4rev1 |
WP1 - CFA - OECD |
- |
En & Fr |
§ / 6 |
1st revision and final version of Part 4 of the document
CFA(76)7: Reservations on the Articles |
29/04/77 |
DAF/CFA/77.10 |
WP6 - CFA - OECD |
- |
En |
- |
The document contains a questionnaire on transfer pricing
related to tangible assets sent to selected MNEs |
16/05/77 |
DAF/CFA/77.14 |
WP6 - CFA - OECD |
- |
En! |
- |
The document discusses the problem of whether and how costs
for services should be paid between the different members of the group. |
25/05/77 |
DAF/CFA/77.17 |
WP6 - CFA - OECD |
- |
En! |
- |
The document discusses the actual work and possible
co-operation between the two international organizations in elaborating a
manual of practices in transfer prices of goods. |
06/06/77 |
DAF/CFA/77.19 |
WP6 - CFA - OECD |
- |
En! |
- |
Decisions of the Working Party concerning the documents of
Transfer of Technology, Services and Goods |
04/08/77 |
DAF/CFA/77.23 |
WP6 - CFA - OECD |
UK |
En! |
- |
United Kingdom´s note concerning the document DAF/CFA/77.14
concerning the transfer prices of Services |
17/08/77 |
DAF/CFA/77.25 |
WP6 - CFA - OECD |
US |
En! |
- |
United States note concerning the document DAF/CFA/77.14
concerning the transfer prices of Services |
17/08/77 |
DAF/CFA/77.24 |
WP6 - CFA - OECD |
- |
En! |
- |
The problem of Customs valuation in cases of transfer pricing
of tangible assets a document by the Customs Co-operation Council |
13/09/77 |
DAF/CFA/77.27 |
WP6 - CFA - OECD |
- |
En! |
- |
The document contains an introductory note by the Swiss
delegate concerning the transfer prices of industrial property other than
patents and know how with special focus on trademarks. |
16/09/77 |
DAF/CFA/77.14rev1 |
WP6 - CFA - OECD |
- |
En |
- |
The document contains the revised draft of the document
DAF/CFA/77.14 taking into account the submitted opinions of the US and UK
delegates |
28/09/77 |
DAF/CFA/WP1/77.11 |
CFA - OECD |
- |
En |
Part II / 29 |
This report contains an analysis of the relationship between
the OECD Draft and bilateral Convention signed between seven OECD member
countries developing countries during the period July 1967 to November
1976. |
30/09/77 |
DAF/CFA/77.29 |
WP6 - CFA - OECD |
CH |
En! |
- |
The document contains comments by the Delegate for Switzerland
on the Secretariat note DAF/CFA/77.14 |
07/10/77 |
DAF/CFA/WP1/77.12 |
WP1 - CFA - OECD |
US |
En |
4 / 12 |
The document contains the main differences between the OECD
and the United States Model Convention |
17/11/77 |
DAF/CFA/77.34 |
WP6 - CFA - OECD |
- |
- |
- |
The document contains the summary of the discussion of the
working group concerning the transfer prices of goods. |
18/11/77 |
DAF/CFA/77.35 |
WP6 - CFA - OECD |
- |
En |
- |
The document contains an analysis of the answers by BIAC to
the list of questions on the transfer of goods |
01/12/77 |
DAF/CFA/77.36 |
WP6 - CFA - OECD |
CH |
En |
- |
The document contains a note by the delegate from Switzerland
concerning the transfer prices for tangible assets. |
08/12/77 |
DAF/CFA/77.37 |
WP6 - CFA - OECD |
- |
En |
- |
The document contains as agreed the point mentioned by the
delegate of Finland, transfer prices of “loss products”. |
09/12/77 |
CFA(77)12 |
CFA - OECD |
- |
En |
IV / 4 |
Discussion of national treatment in the international
investment treaties and multinational enterprises by the OECD |
19/12/77 |
DAF/CFA/77.39 |
WP6 - CFA - OECD |
- |
En! |
- |
The document contains decisions over: Intra-group services,
Goods (Tangible Assets)and meeting of the BIAC. |
20/12/77 |
CFA(77)15 |
WP6 - CFA - OECD |
- |
En |
- |
Report on the intra-group transfer of services, in particular
administrative, technical and commercial |
22/12/77 |
DAF/CFA/77.35 (Add) |
WP6 - CFA - OECD |
- |
En |
- |
Amendments to the document DAF/CFA/77.35 taking into account
the replies of MNE's from Sweden and Switzerland |
22/12/77 |
DAF/CFA/77.40 |
WP6 - CFA - OECD |
- |
En |
- |
The document contains the list of items to be discussed with
BIAC at the joint meeting of March 1978 |
05/01/78 |
CFA(77)15 (Add) |
WP6 - CFA - OECD |
- |
En |
- |
Amendments made by the delegate from Germany to the document
CFA(77)15 |
06/02/78 |
DAF/CFA/WP6/78 |
WP6 - CFA - OECD |
- |
En |
- |
Provisional document not committed to an OECD government
containing the transfer price for goods or tangible assets. |
15/03/78 |
CFA(78)1 |
WP8/WG2 - CFA - OECD |
- |
En |
b / 14 |
Transfer pricing problem related to Shipping activities |
24/03/78 |
DAF/CFA/WP6/78.6 |
WP6 - CFA - OECD |
- |
En |
- |
Decisions taken at the meeting of Transfer prices WP6
concerning: Meeting with BIAC, Future work, Services, Goods |
30/05/78 |
CFA(77)15rev1 |
WP6 - CFA - OECD |
- |
En |
- |
1st revision of the document CFA(77)15 concerning certain
intra-group transfer services in particular administrative, technical and
commercial services |
21/08/78 |
CFA(78)1 (Corr) |
WP8/WG2 - CFA - OECD |
- |
Fr |
- |
Corrections to the document CFA(78)1 concerning the taxation
of International Shipping |
05/09/78 |
DAF/CFA/78.12 |
WP6 - CFA - OECD |
- |
En |
- |
The document contains problems and possible solutions of the
difficulties facing tax authorities in relations to transfer pricing of
goods. |
05/09/78 |
DAF/CFA/78.13 |
WP6 - CFA - OECD |
- |
En |
- |
The report discusses the transfer prices of goods, services or
technology and loans made between affiliated companies |
05/09/78 |
DAF/CFA/78.14 |
WP6 - CFA - OECD |
- |
En |
- |
The report discusses the transfer prices of advertising
charges (services) |
05/09/78 |
DAF/CFA/78.15 |
WP6 - CFA - OECD |
- |
En |
- |
The document discusses the transfer pricing, Legal and
economic aspects of the trademark |
06/11/78 |
DAF/CFA/WP6/78.10 |
WP6 - CFA - OECD |
- |
En |
- |
The document contains a note on the use of trademarks (Legal
and economic aspects) |
06/11/78 |
DAF/CFA/WP6/78.9 |
WP6 - CFA - OECD |
- |
En |
- |
The document contains problems and possible arms length
solutions of the difficulties facing tax authorities in relations to transfer
pricing of goods. |
07/11/78 |
DAF/CFA/WP6/78.11 |
WP6 - CFA - OECD |
- |
En |
- |
The document contains a note with the introduction and summary
of transfer pricing issues, the arm´s length principle and article 9 of the
OECD Convention Model |
24/11/78 |
DAF/CFA/WP6/78.13 |
WP6 - CFA - OECD |
- |
En |
- |
The document contains a note on the tax treatment of
Advertising Charges between affiliated
enterprises. |
23/07/74 |
DAF/CFA/74.9 |
CFA - OECD |
- |
En |
7b / 3 |
The document mentions that WP6 is working on transfer prices
and tax heavens |
12/03/79 |
CFA(79)1 |
CFA - OECD |
- |
En |
- |
Consolidated version of the TP report containing the
guidelines and specific considerations concerning goods, technology and
trademarks, certain intra group services, loans; a recommendation of the OECD
Council is provided in the annex |
02/04/79 |
DAF/CFA/WP1/79.1 |
WP6 - CFA - OECD |
- |
En |
- |
Program of the future work of WP6 |
18/10/79 |
DAF/CFA/WP6/79.2 |
WP6 - CFA - OECD |
- |
En |
- |
Note on the economic double taxation caused by transfer
pricing adjustements and possible solutions |
26/10/79 |
DAF/CFA/WP6/79.2 (Add) |
WP6 - CFA - OECD |
- |
- |
- |
Proposal for setting pricing controversies through binding
arbitrations |
26/10/79 |
DAF/CFA/WP6/79.3 |
WP6 - CFA - OECD |
UK |
En |
- |
Note by the UK Delegation on transfer pricing in the banking
sector |
12/11/79 |
DAF/CFA/WP6/79.4 |
WP6 - CFA - OECD |
DE |
En |
- |
Note by the German Delegation concerning transfer pricing
methods in the case of services |
02/04/80 |
DAF/CFA/WP6/80.5 |
WP6 - CFA - OECD |
- |
En & Fr |
- |
Response of the BIAC's Committee on Taxation and Fiscal Policy
to the OECD's Report on Transfer Pricing and Multinational Enterprises, with
comments and supplementary views |
08/04/80 |
DAF/CFA/WP6/80.4 |
WP6 - CFA - OECD |
- |
En |
- |
BIAC'S reply to the OECD's questionnaire on the risk of double
taxation due to corresponding adjustemnts |
09/04/80 |
DAF/CFA/WP6/79.2rev1 |
WP6 - CFA - OECD |
- |
En |
- |
First revision to document DAF/CFA/WP6/79.2 (English text
missing) |
11/04/80 |
DAF/CFA/WP6/79.2rev1 (Corr) |
WP6 - CFA - OECD |
- |
En! |
- |
Corrigendum to document DAF/CFA/WP6/79.2 (1st Revision) |
09/06/80 |
DAF/CFA/WP6/80.9 |
WP6 - CFA - OECD |
- |
En |
- |
Questionnaire on taxation of multinational banking
enterprises |
15/07/80 |
DAF/CFA/WP6/80.10 |
WP6 - CFA - OECD |
- |
En |
- |
Draft report on the problems arising from corresponding
adjustements |
09/12/80 |
DAF/CFA/WP6/80.11 |
WP6 - CFA - OECD |
- |
En |
- |
Decisions taken by WP6 on various issues of transfer pricing:
corresponding adjustments, banking sector and the BIAC comments |
03/04/81 |
DAF/CFA/WP6/81.3 |
WP6 - CFA - OECD |
- |
En |
- |
Report on the possibility to solve the problem of
corresponding adjustments through MAP (current situation and possible
improvements) |
15/04/81 |
DAF/CFA/WP6/81.4 |
WP6 - CFA - OECD |
- |
En |
- |
Report on the issue of attributing central management services
to subsidiaries |
03/11/81 |
DAF/CFA/WP6/81.12 |
WP6 - CFA - OECD |
- |
En |
- |
Report on problems arising from the corresponding adjustments
and on possible solution through MAP |
10/02/82 |
DAF/CFA/WP6/81.12rev1 |
WP6 - CFA - OECD |
- |
En |
- |
Revised version of report DAF/CFA/WP6/81.12 |
24/03/82 |
DAFFE/CFA/WP1/82.2 |
WP1 - CFA - OECD |
- |
En |
- |
Clarification on the scope of the article 25 in cases of
corresponding adjustments under art 9(2) |
28/06/82 |
DAFFE/CFA/WP1/82.6 |
WP1 - CFA - OECD |
- |
Fr |
IV/ 1 |
Discussion on the applicability of MAP in art 9(2) cases |
26/08/82 |
DAFFE/CFA/WP6/82.2 |
WP6 - CFA - OECD |
- |
En |
- |
Extensive report on transfer pricing and attribution of
profits in the banking sector |
22/03/83 |
DAFFE/CFA/WP6/83.2 |
WP6 - CFA - OECD |
- |
En |
- |
Extensive report from the Dutch Delegation on the problem of
the allocation of central management and services costs in a multinational
enterprise |
09/09/83 |
DAFFE/CFA/WP6/83.2rev1 |
WP6 - CFA - OECD |
- |
- |
- |
Revised version of report DAFFE/CFA/WP6/83.2 on the problem of
the allocation of central management and services costs in a multinational
enterprise |
10/02/84 |
DAFFE/CFA/WP1/84.1 |
WP1 - CFA - OECD |
- |
En |
- |
Report by the German Delegation on the improper use of tax
treaties through "base companies" |
17/09/84 |
DAFFE/CFA/WP1/84.1rev1 |
WP1 - CFA - OECD |
- |
En |
- |
First revision to report DAFFE/CFA/WP1/84.1 |
12/10/84 |
DAFFE/CFA/WP6/84.6 |
WP6 - CFA - OECD |
- |
En |
- |
Introductiory note explaining the aim of the work of the WP in
this field |
12/02/85 |
DAFFE/CFA/WP1/84.1rev2 |
WP1 - CFA - OECD |
- |
En |
- |
Second revision revision to report DAFFE/CFA/WP1/84.1 |
26/03/85 |
CFA/WP6/WD/85.1 |
WP6 - CFA - OECD |
- |
- |
- |
Report by the German Institute of Accountants concerning the
problem of double taxation arising from corresponding adjustements, and
possible solutions |
30/05/85 |
DAFFE/CFA/WP6/85.6 |
WP6 - CFA - OECD |
- |
En |
Annex/ 5 |
Discussion on the US proposal of the Foreign Sales
Corporations rules as a safe haven for small exportes |
15/09/86 |
DAFFE/CFA/WP1/86.8 |
WP1 - CFA - OECD |
- |
En |
5 / 20 |
BIAC's review of tax issues related to specific articles of
the 1977 OECD MC |
08/01/87 |
DAFFE/CFA/86.25 |
CFA - OECD |
- |
En |
5 / 15 |
BIAC's review of tax issues related to specific articles of
the 1977 OECD MC; the document is submittee to the CFA for information |
22/12/88 |
DAFFE/CFA/WP6/88.6rev1 |
WP6 - CFA - OECD |
- |
En |
- |
Report on Member States domestic provisions concerning the
request of information in order to decide whether an offshore payment
occurred at arm's length |
21/07/88 |
DAFFE/CFA/WP1/88.7 |
WP1 - CFA - OECD |
- |
Fr |
- |
Report on the provisions of the 1977 MC which should be reviewed |
09/02/89 |
DAFFE/CFA/WP1/89.3 |
WP1 - CFA - OECD |
- |
En |
- |
The note reproduces the observations and reservations to the
1977 MC |
25/04/89 |
DAFFE/CFA/WP6/89.9 |
WP1 - CFA - OECD |
- |
En |
- |
Note on an alternative method favoured by the US Government |
09/08/89 |
DAFFE/CFA/WP1(89)3rev1 |
WP1 - CFA - OECD |
- |
En |
- |
The note reproduces the observations and reservations to the
1977 MC |
29/01/90 |
DAFFE/CFA/WP1/89.3rev2 |
WP1 - CFA - OECD |
- |
En |
§ / 15,16 |
2nd Revision of the Observations and Reservations of the 1977
Model Convention; Answers received from the letter CFA(88)254 of 3rd October
1988. |
22/03/90 |
DAFFE/CFA/WP1/89.3rev3 |
WP1 - CFA - OECD |
- |
En |
§ / 15,16 |
3rd Revision of the Observations and Reservations of the 1977
Model Convention; Answers received from the letter CFA(88)254 of 3rd October
1988. |
11/10/91 |
DAFFE/CFA/WP1/M(91)2 |
WP1 - CFA - OECD |
- |
En |
VI / 4 |
Adoption of the document Transfer pricing with amendments of
the document DAFFE/CFA/WP1(91)4/REV1 |
18/03/92 |
DAFFE/CFA/WP6(92)3 |
WP6 - CFA - OECD |
- |
En |
- |
Proposed Schedule for the revision of the 1979 Report of
Transfer Pricing and Multinational Enterprises |
04/10/92 |
DAFFE/CFA/WP6/M(92)1 |
WP6 - CFA - OECD |
- |
En |
- |
Election of a vice-president, Joint Meeting with BIAC, Tax
aspects od Mergers and acquisitions, Monitoring TP, Revision of the 1979
Report, Taxation of new Financial Instruments, Recent Developments and other
Business |
17/11/92 |
DAFFE/CFA/WP6(92)7 |
WP6 - CFA - OECD |
- |
En |
- |
Proposed amendments to the report on the taxation of new
financial instruments DAFFE/CFA/WP6(92)12 |
07/12/92 |
DAFFE/CFA(92)30 |
CFA - OECD |
- |
En |
- |
Proposed Schedule for the revision of the 1979 Report of
Transfer Pricing and Multinational Enterprises |
29/01/93 |
DAFFE/CFA/WP6/M(92)2 |
WP6 - CFA - OECD |
- |
En |
IV / 3 |
Revision on the 1979 Report on Transfer Pricing |
05/07/93 |
DAFFE/CFA/M(93)2 |
CFA - OECD |
- |
En |
III / 4,5 |
Discussion of Transfer Prices and related issues; documents
DAFFE/CFA(93)11, DAFFE/CFA/WP6(93)3/REV1, DAFFE/CFA/WD(93)13,
DAFFE/CFA/WD(93)17 |
16/12/93 |
DAFFE/CFA(94)13 |
WP6 - CFA - OECD |
- |
En |
- |
Report concerning the arm´s length principle and Transfer
pricing guidelines for multinational enterprises and tax administrations |
28/01/93 |
DAFFE/CFA/M(94)1 |
CFA - OECD |
- |
En |
- |
Discussion concerning transfer pricing and related issues
documents DAFFE/CFA(94)13, DAFFE/CFA/WD(94)6, DAFFE/CFA/WD(94)19 |
01/07/94 |
DAFFE/CFA/M(94)2 |
CFA - OECD |
- |
En |
- |
Discussion and decision by the CFA concerning the revision of
the 1979 report on transfer pricing; Documents DAFFE/CFA(94)19,
DAFFE/CFA(94)21, DAFFE/CFA(94)21/REV1, DAFFE/CFA(94)21/REV2, DAFFE/CFA(94)24,
DAFFE/CFA/WD(94)29 |
07/09/94 |
DAFFE/CFA/WP1/MR(94)8 |
WP1 - CFA - OECD |
- |
En |
§ / 4 |
The document contains the amendments to the observations and
reservations for inclusion in the 1995 update to the model tax
convention |
04/11/94 |
DAFFE/CFA/WP1/MR(94)17 |
WP1 - CFA - OECD |
- |
En |
II / 4 |
Conditions made or imposed and conditions between independent
enterprises; Discussion of the issues (Preparing for the 1995 update) of the
note DAFFE/CFA/WP1/MR(94)6/REV1 |
08/11/94 |
DAFFE/CFA/WP1(94)9 |
WP1 - CFA - OECD |
- |
En |
§ / 16 |
The document contains the probable texts and reservations of
the 1995 Update and additional items that have not been formally agreed |
22/11/94 |
DAFFE/CFA/WP6(94)3 |
WP6 - CFA - OECD |
- |
En |
- |
Outline of the report on arbitration of transfer pricing
issues |
06/03/95 |
DAFFE/CFA/WP6/WD(95)1 |
WP6 - CFA - OECD |
- |
En! |
- |
Pre-Ruling Consultative Document concerning the Arm’s length
methodologies and documentation |
13/04/95 |
DAFFE/CFA/WP6(95)7 |
WP6 - CFA - OECD |
- |
En |
- |
The document discusses the key characteristics of Japanese
transfer pricing (TP) provisions |
11/05/95 |
DAFFE/CFA/WP6/M(95)1 |
WP6 - CFA - OECD |
- |
E |
-- |
Discussion of the Transfer Prices Report by WP6; Guidelines
part I and II, Joint meeting with the BIAC, Future Work |
29/06/95 |
C(95)126 |
Council - OECD |
- |
En |
- |
Council´s draft recommendations on the determination of
transfer pricing |
04/08/95 |
C(95)126/FINAL |
Council - OECD |
- |
- |
- |
Council´s recommendations to Governments of Member countries
on the determination of transfer pricing |
23/08/95 |
DAFFE/CFA/WP1/WD(95)17 |
WP1 - CFA - OECD |
- |
En |
31-34 / 5 |
Changes to the OECD model tax convention and its commentaries
from 1977-1995 |
07/09/95 |
DAFFE/CFA/WP6(95)9 |
WP6 - CFA - OECD |
- |
En |
- |
The council recommendation and suggestions on monitoring the
implementation of the transfer pricing guidelines |
19/12/95 |
DAFFE/CFA(95)16 |
CFA - OECD |
- |
- |
§ / 21 |
1995 changes to the OECD Model Convention and changes to the
observation and reservation |
14/01/96 |
DAFFE/CFA/WP1(96)1 |
WP1 - CFA - OECD |
- |
En |
§ / 9 |
Comments of the BIAC on the Model Tax Convention to Working
Party 1 |
17/01/96 |
DAFFE/CFA/WP6/M(95)2 |
WP6 - CFA - OECD |
- |
En |
- |
Discussions of WP6 concerning the peer review of the transfer
pricing practices, transfer pricing guidelines, monitoring procedures, TP in
Korea and Poland and Hungary |
01/02/96 |
DAFFE/CFA/WP1/MR(96)3 |
WP1 - CFA - OECD |
- |
En |
- |
Discussion of the Steering Group concerning Ancillary of
International Airlines, Definition of international traffic and application
of article 8 to investment income |
05/08/96 |
DAFFE/CFA/WP6/M(96)1 |
WP6 - CFA - OECD |
- |
En |
- |
The review of Poland´s TP, peer review of TP practices,
monitoring procedures, administrative aspects of TP and others. |
18/11/96 |
DAFFE/CFA/WP6(96)12 |
WP6 - CFA - OECD |
- |
En! |
- |
Monitoring transfer pricing developments of Members Committee
on Fiscal Affairs |
22/11/96 |
DAFFE/CFA/WP6(96)10 |
WP6 - CFA - OECD |
- |
En |
- |
BIAC Statement regarding the Final Regulations under Section
6662(e) Internal Revenue Code (IRC) concerning Accuracy-Related
Penalties |
26/11/96 |
DAFFE/CFA/WP6(96)13 |
WP6 - CFA - OECD |
AU |
En! |
- |
Note by the Delegate from Australia on the comments from BIAC
[DAFFE/CF A/WP6(96)8]) |
28/11/96 |
DAFFE/CFA/WP6(96)11 |
WP6 - CFA - OECD |
- |
En! |
- |
Draft BIAC comments on chapter VII of the OECD transfer
pricing guidelines: cost contribution arrangements |
28/11/96 |
DAFFE/CFA/WP6(96)8 |
WP6 - CFA - OECD |
- |
En |
- |
Comments from BIAC concerning the monitoring the application
of and adherence to the OECD transfer pricing guidelines by member
countries |
24/02/97 |
DAFFE/CFA/WP6/M(96)2 |
WP6 - CFA - OECD |
- |
En |
- |
Discussion of WP6 concerning the transfer pricing Guidelines,
Peer review of TP practices, comments by the BIAC |
28/02/97 |
DAFFE/CFA/WP6(97)4 |
WP6 - CFA - OECD |
- |
En |
- |
The document discusses the process of implementing the council
recommendation on monitoring the application of the OECD transfer pricing
guidelines : revised guidelines for conducting peer reviews |
13/03/97 |
DAFFE/CFA/WP6(97)5 |
WP6 - CFA - OECD |
- |
En |
- |
The document discusses the process of implementing the council
recommendation on monitoring the application of the OECD transfer pricing
guidelines: the role of the BIAC |
21/03/97 |
DAFFE/CFA/WP6(96)12/REV1 |
WP6 - CFA - OECD |
NZ |
En |
- |
Monitoring transfer pricing developments ; New Zealand revised transfer pricing
legislation |
25/04/97 |
DAFFE/CFA/WP6(97)4/REV |
WP6 - CFA - OECD |
- |
En |
- |
The process of implementing the council recommendation on
monitoring the application of the OECD transfer pricing guidelines:1st
revision revised guidelines for conducting PEER reviews |
13/05/97 |
DAFFE/CFA/WP6(97)5/REV1 |
WP6 - CFA - OECD |
- |
En |
- |
The document discusses the process of implementing the council
recommendation on monitoring the application of the OECD transfer pricing
guidelines: 1st revision the role of the BIAC |
18/06/97 |
DAFFE/CFA/WP6/M(97)1 |
WP6 - CFA - OECD |
- |
En |
- |
Discussion of WP6 Concerning; TP Guidelines, PEER review of TP practices and monitoring |
20/06/97 |
DAFFE/CFA/WP1(97)10/CORR1 |
WP1 - CFA - OECD |
- |
En |
PARTI II, 7 / 3 |
The 1997 update to the model tax convention; amendments for
the 1997 model |
18/07/97 |
DAFFE/CFA/WD(97)11 |
CFA - OECD |
- |
En |
- |
The documents contains a note by the secretariat concerning
the guidelines for monitoring procedures on the OECF transfer pricing
guidelines and the involvement of BIAC: version for BIAC and possible
insertion as an annex to the guidelines |
20/08/97 |
DAFFE/CFA/WP1(97)12 |
WP1 - CFA - OECD |
- |
En |
23 / 10 |
Changes to Belgium’s reservations and observations |
18/09/97 |
DAFFE/CFA/WD(97)11/REV1 |
CFA - OECD |
- |
En |
- |
The document contains the guidelines for monitoring procedures
on the OECD transfer pricing guidelines and the involvement of the business
community ;Annex to "Transfer
Pricing Guidelines for Multinational Enterprises and Tax
Administrations". |
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