IFA: Practical Experience with the OECD Transfer Pricing Guidelines: Practical Experience with the OECD Transfer Pricing Guidelines

by International Fiscal Association (IFA)

Overview

The 1998 seminar considered whether the OECD Guidelines had started to influence tax legislation or the practice of Revenue authorities. The seminar reviewed recent developments in transfer pricing legislation throughout the world. It considered the results of a questionnaire to multinational groups in the Association, and the views of panel members and other participants.

Product Details

ISBN-13:	9789041112989
Publisher:	Wolters Kluwer
Publication date:	12/01/1999
Series:	IFA Congress Series Set , #23
Pages:	52
Product dimensions:	6.14(w) x 9.21(h) x 0.14(d)

Table of Contents

Introductory Notes
Works of the OECD I; J. Owens
Works of the OECD II; D. Lütti
Allocation of Profits under Article 14
To Which Extent do Employees Assigned to a Subsidiary Constitute a Permanent Establishment of the Parent Company?
Appendix 1: The OECD Committee on Fiscal Affairs
Appendix 2: Outline on Article 14
Appendix 3: Outline on Employees as a Permanent Establishment
Appendix 4: The Origins of OECD Model Articles 7, 14 and 15

Editorial Reviews

Presents the material that was prepared by a panel of international tax experts to address the subject. They consider not only the technical aspects of secondary adjustments, but also the underlying philosophical question of whether there should be any at all and if so what appropriate limitations might be. They discuss a labyrinth of potential adjustments that could flow from the primary transfer pricing adjustment, as well as set-offs and corresponding adjustments. No index. Annotation c. Book News, Inc., Portland, OR (booknews.com)

Booknews