OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2009; and Transfer Pricing Features of Selected Countries 2009

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. 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. 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.