Wednesday, 6 June 2012

OECD invites comments on certain transfer pricing timing issues

The OECD Secretariat invites public comments on certain timing issues related to transfer pricing, in connection with the work of Working Party No. 6 on intangibles and other projects. Modifications to the Transfer Pricing Guidelines on these issues have been discussed by Working Party No. 6 delegates. Those modifications are not agreed by all countries. However, they raise certain difficult issues on which comment by the business community is specifically requested by the Secretariat.
The paragraphs under consideration highlight the fact that OECD member countries follow two different approaches in applying the arm’s length principle. The existence of these different approaches to applying the arm’s length principle raises a number of difficult issues. It would be helpful to the Secretariat to have comments on the practical problems caused by the existence of these two different approaches.
Source: OECD