Comments on the OECD final report: Chapter IV

Administrative approaches to avoiding and resolving transfer pricing disputes and Chapter V: documentation

By: Huub M.M. Bierlaagh and Steef B. Huibregtse.

The Guidelines which form the subject of this issue are a compilation and revision of the

1979 Report Transfer Pricing and Multinational Enterprises, the 1984 Report Transfer Pricing and Multinational Enterprises: Three Taxation Issues and the 1987 Report Thin Capitalization. Administrative issues and documentation have not earlier been dealt with comprehensively as a separate subject in relation to transfer pricing. The Final Report deals with these aspects in Chapters IV and V.

The administrative topics discussed are:

• transfer pricing compliance practices;

• corresponding adjustments and the mutual agreement procedure;

• simultaneous tax examinations;

• safe harbours;

• advance pricing arrangements; and

• arbitration.

This article discusses these topics in the same order as the Final OECD Report.

Download the full article:

ITPJ 1995 p. 21 Comments on the OECD final report .pdf

Download PDF • 1.24MB