OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2009 Edition and Transfer Pricing Features of Selected Countries 2009
Editors: Aurobindo Ponniah (IBFD) and Antoine Glaize (Taxand)
Summary

The increase in global trade and foreign direct investment has seen a large rise in companies operating across national borders. The growth of these multinational companies (MNCs) has been closely followed by the issue of inter-company transfer prices being used to reduce taxable profits. Today, transfer pricing is one of the most important issues facing MNCs as they attempt to fairly distribute their profits amongst each company in the group while dealing with tax authorities who are implementing transfer pricing regulations and strengthening enforcement in order to prevent a loss of revenue. The result of which is that transfer pricing controversies have become a major tax issue for companies.

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This reference booklet, in addition to containing the OECD’s Transfer Pricing Guidelines, provides an excellent overview of transfer pricing rules and regulations in 29 countries and is a handy guide for those actively working in the field of transfer pricing.

OECD TP Guidelines
Main contents

Part A

  • The official text of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (Condensed version)
  • Including transfer pricing glossary

Part B

  • Country surveys providing a concise description of the transfer pricing regulations. The information is discussed in a domestic as well as in an international context. Including:
    • Tax authority and law
    • Rulings and guidelines
    • Methodologies
    • Comparability analysis
    • Disclosure/documentation requirements
    • Mutual agreement procedures (MAP)
    • Advanced pricing agreement (APA)
    • Safe harbour provisions
    • Transfer pricing audits
    • Penalties
  • Countries selected on the basis of economic importance and amount of transfer pricing activity.
  • Common chapter outline allows easy and direct comparisons between countries.
Countries covered
Argentina, Australia, Belgium, Brazil, Canada, Chile, China, France, Germany, India, Ireland, Italy, Japan, Malaysia, Netherlands, New Zealand, Poland, Portugal, Russia, Singapore, South Korea, Spain, Sweden, Switzerland, Thailand, Turkey, United Kingdom, United States, Venezuela.
About the Editors

Aurobindo Ponniah is the Head of the IBFD’s Asia-Pacific office located in Malaysia, where he has overall responsibility for IBFD’s databases, government consulting, research, training and documentation activities in the region, servicing a range of clients from governments, advisory firms and MNCs.


Antoine Glaize is the Taxand Global Transfer Pricing Team leader which brings together Taxand transfer pricing specialists from nearly 50 countries. He is also a partner with Arsene Taxand, the Taxand network’s member firm in France. Antoine focuses on delivering global transfer pricing projects for MNCs relying on his breadth of experience over the last 15 years. As well as his time with the French Ministry of Economy, Finance and Industry, where he was in charge of transfer pricing and advance pricing agreements, Antoine has worked client-side and in top global accountancy firms.

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