Transfer Pricing: OECD Transfer Pricing Rules and Guidelines (Portfolio 6936)

Samuel_Maruca

Samuel Maruca

Partner

Covington & Burling LLP

Headshot of Michael Mcdonald

Michael McDonald, Ph.D.

Executive Director - National Tax

Ernst & Young LLP

Headshot of Jason M. Osborn

Jason M. Osborn

Partner

Mayer Brown LLP

At a glance

I. Introduction

II. Chapter I of the Guidelines: The Arm’s Length Principle

III. Transfer Pricing Methods

IV. Comparability Analysis

V. Administrative Approaches to Avoiding and Resolving Transfer Pricing Disputes

VI. Documentation

VII. Special Considerations for Intangible Property

VIII. Special Considerations for Intra-Group Services

IX. Cost Contribution Arrangements

X. Transfer Pricing Aspects of Business Restructurings

XI. Transfer Pricing Guidance on Financial Transactions

Abstract

Practitioners will most often encounter the Guidelines in tax audits and competent authority proceedings where the Guidelines are used to shed light on the transfer pricing regulations of a particular country or to reconcile seemingly contradictory transfer pricing rules of two countries. The OECD Guidelines were heavily influenced by transfer pricing developments in the United States, and the Portfolio draws attention to analogs and potential discrepancies between the Guidelines and the U.S. transfer pricing regulations. The Guidelines are organized into ten chapters with alphabetically lettered subchapters; this Portfolio discusses the chapters in order for ease of reference.

 

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