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International - OECD Publishes Revised Guidelines on Transfer Pricing, Accommodating 15 Years of Juggling the Arm’s Length Principle in a Globalizing Business World

I. Verlinden; I. Dykes; A. Casley; G. Stone; A. Katz; E. Finch; R. Thomas; N. Houseman; A. Ross; L. de Preter; R. Mitra; M. Diepstraten; Y. Mondelaers
International Transfer Pricing Journal, 2010 (Volume 17), No 5
30 August 2010
The OECD has now approved the proposed revisions to Chaps. I through III of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Authorities. The revised text results in major changes to the OECD's authorized approach, which will have a significant impact on the application of transfer pricing analysis in many parts of the world. In addition, the OECD has simultaneously published a new Chap. IX to the Transfer Pricing Guidelines related to business restructuring. The revisions to Chaps. I through III are the result of several years of work on comparability in general and the use of profit-based methods in particular. Consequently the significant changes are broadly as expected, but there are some developments on more detailed points that have arisen over the last few months. Like the Transfer Pricing Guidelines as a whole, the new Chap. IX reflects the OECD's desire to clarify the application of Art. 9 of the OECD Model Tax Convention when applied to complex real-life situations.
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