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In a global economy where multinational enterprises (MNEs) play a prominent role, governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdiction and that the tax base reported by MNEs in their country reflects the economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation. The OECD Transfer Pricing Guidelines provide guidance on the application of the “arm’s length principle”, which is the international consensus on the valuation of cross-border transactions between associated enterprises.
This January 2022 edition includes the revised guidance on the application of the transactional profit method and the guidance for tax administrations on the application of the approach to hard-to-value intangibles agreed in 2018, as well as the new transfer pricing guidance on financial transactions approved in 2020. Finally, consistency changes have been made to the rest of the OECD Transfer Pricing Guidelines. The OECD Transfer Pricing Guidelines were approved by the OECD Council in their original version in 1995.
This 2017 edition of the OECD Transfer Pricing Guidelines incorporates the substantial revisions made in 2016 to reflect the clarifications and revisions agreed in the 2015 BEPS Reports on Actions 8-10 Aligning Transfer pricing Outcomes with Value Creation and on Action 13 Transfer Pricing Documentation and Country-by-Country Reporting. It also includes the revised guidance on safe harbours approved in 2013 which recognises that properly designed safe harbours can help to relieve some compliance burdens and provide taxpayers with greater certainty. Finally, this edition also contains consistency changes that were made to the rest of the OECD Transfer Pricing Guidelines. The OECD Transfer Pricing Guidelines were approved by the OECD Council in their original version in 1995.
The OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations provide guidance on the application of the “arm’s length principle”, which is the international consensus on transfer pricing, i.e. on the valuation, for tax purposes, of cross-border transactions between associated enterprises. In a global economy where multinational enterprises (MNEs) play a prominent role, transfer pricing is high on the agenda of tax administrators and taxpayers alike. Governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdictions and that the tax base reported by MNEs in their respective countries reflect the economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation that may result from a dispute between two countries on the determination of an arm’s length remuneration for their cross-border transactions with associated enterprises.
After having been originally published in 1979, the OECD Transfer Pricing Guidelines were approved by the OECD Council in their original version in 1995. A limited update was made in 2009, primarily to reflect the adoption, in the 2008 update of the Model Tax Convention, of a new paragraph 5 of Article 25 dealing with arbitration, and of changes to the Commentary on Article 25 on mutual agreement procedures to resolve cross-border tax disputes. In the 2010 edition, Chapters I-III were substantially revised, with new guidance on: the selection of the most appropriate transfer pricing method to the circumstances of the case; the practical application of transactional profit methods (transactional net margin method and profit split method); and on the performance of comparability analyses. Furthermore, a new Chapter IX, on the transfer pricing aspects of business restructurings, was added. Consistency changes were made to the rest of the Guidelines.
OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations provides guidance on the application of the "arm's length principle" for valuation for tax purposes of cross-border transactions between associated enterprises. In a global economy where multinational enterprises (MNEs) play a prominent role, governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdiction and that the tax base reported by MNEs in their country reflects the economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation that may result from a dispute between two countries on the determination of the arm’s length remuneration for their cross-border transactions with associated enterprises.
The OECD Transfer Pricing Guidelines clarifies these issues and were originally approved by the OECD Council in 1995. In this 2009 edition, some amendments have been made to Chapter IV, primarily to reflect the adoption, in the 2008 update of the Model Tax Convention, of a new paragraph 5 of Article 25 dealing with arbitration, and of changes to the Commentary on Article 25 on mutual agreement procedures to resolve cross-border tax disputes.
The 2018 edition analyses tourism performance and policy trends across 49 OECD countries and partner economies. It highlights the need for coherent and comprehensive approaches to tourism policy making, and the significance of the tourism economy, with data covering domestic, inbound and outbound tourism, enterprises and employment, and internal tourism consumption. Thematic chapters explore how understanding the potential impacts of megatrends can better shape the future of tourism, and the need for a shift towards investment and financing for sustainable tourism growth.
In accordance with decisions made by the FDI, the OECD has initiated surveys on fiscal decentralisation for the purpose of providing international comparisons on the design of fiscal systems across levels of government. The FDI is a joint initiative of the OECD, the World Bank, USAID, the Council of Europe, The Open Society Institute, UNDP and OECD Member countries to assist transition economies in Central and Eastern Europe in carrying out intergovernmental reforms. In 2000 the surveys took place in six countries: three OECD Member countries, the Czech Republic, Hungary and Poland, and the three Baltic States, Estonia, Latvia and Lithuania. In "Fiscal Design Surveys across Levels of Government" OECD Tax Policy Studies, no 7, 2001, the overall concept of the surveys and the comparative results for the six countries are brought. The full country reports are available through the OECD iLibrary, www.OECD-iLibrary.org, and the internet site of the OECD Centre for Tax Policy and Administration, www.oecd.org/daf/fa
In accordance with decisions made by the FDI, the OECD has initiated surveys on fiscal decentralisation for the purpose of providing international comparisons on the design of fiscal systems across levels of government. The FDI is a joint initiative of the OECD, the World Bank, USAID, the Council of Europe, The Open Society Institute, UNDP and OECD Member countries to assist transition economies in Central and Eastern Europe in carrying out intergovernmental reforms. In 2000 the surveys took place in six countries: three OECD Member countries, the Czech Republic, Hungary and Poland, and the three Baltic States, Estonia, Latvia and Lithuania. In "Fiscal Design Surveys across Levels of Government" OECD Tax Policy Studies, no 7, 2001, the overall concept of the surveys and the comparative results for the six countries are brought. The full country reports are available through www.OECD-iLibrary.org, and the internet site of the OECD Centre for Tax Policy and Administration, www.oecd.org/daf/fa
In accordance with decisions made by the FDI, the OECD has initiated surveys on fiscal decentralisation for the purpose of providing international comparisons on the design of fiscal systems across levels of government. The FDI is a joint initiative of the OECD, the World Bank, USAID, the Council of Europe, The Open Society Institute, UNDP and OECD Member countries to assist transition economies in Central and Eastern Europe in carrying out intergovernmental reforms. In 2000 the surveys took place in six countries: three OECD Member countries, the Czech Republic, Hungary and Poland, and the three Baltic States, Estonia, Latvia and Lithuania. In "Fiscal Design Surveys across Levels of Government" OECD Tax Policy Studies, no 7, 2001, the overall concept of the surveys and the comparative results for the six countries are brought. The full country reports are available through www.OECD-iLibrary.org, and the internet site of the OECD Centre for Tax Policy and Administration, www.oecd.org/daf/fa
In accordance with decisions made by the FDI, the OECD has initiated surveys on fiscal decentralisation for the purpose of providing international comparisons on the design of fiscal systems across levels of government. The FDI is a joint initiative of the OECD, the World Bank, USAID, the Council of Europe, The Open Society Institute, UNDP and OECD Member countries to assist transition economies in Central and Eastern Europe in carrying out intergovernmental reforms. In 2000 the surveys took place in six countries: three OECD Member countries, the Czech Republic, Hungary and Poland, and the three Baltic States, Estonia, Latvia and Lithuania. In "Fiscal Design Surveys across Levels of Government" OECD Tax Policy Studies, no 7, 2001, the overall concept of the surveys and the comparative results for the six countries are brought. The full country reports are available through www.OECD-iLibrary.org, and the internet site of the OECD Centre for Tax Policy and Administration, www.oecd.org/daf/fa
In accordance with decisions made by the FDI, the OECD has initiated surveys on fiscal decentralisation for the purpose of providing international comparisons on the design of fiscal systems across levels of government. The FDI is a joint initiative of the OECD, the World Bank, USAID, the Council of Europe, The Open Society Institute, UNDP and OECD Member countries to assist transition economies in Central and Eastern Europe in carrying out intergovernmental reforms. In 2000 the surveys took place in six countries: three OECD Member countries, the Czech Republic, Hungary and Poland, and the three Baltic States, Estonia, Latvia and Lithuania. In "Fiscal Design Surveys across Levels of Government" OECD Tax Policy Studies, no 7, 2001, the overall concept of the surveys and the comparative results for the six countries are brought.
In accordance with decisions made by the FDI, the OECD has initiated surveys on fiscal decentralisation for the purpose of providing international comparisons on the design of fiscal systems across levels of government. The FDI is a joint initiative of the OECD, the World Bank, USAID, the Council of Europe, The Open Society Institute, UNDP and OECD Member countries to assist transition economies in Central and Eastern Europe in carrying out intergovernmental reforms. In 2000 the surveys took place in six countries: three OECD Member countries, the Czech Republic, Hungary and Poland, and the three Baltic States, Estonia, Latvia and Lithuania. In "Fiscal Design Surveys across Levels of Government" OECD Tax Policy Studies, no 7, 2001, the overall concept of the surveys and the comparative results for the six countries are brought.
This report is part of the OECD Tax Policy Reviews. The Reviews are intended to provide independent, comprehensive and comparative assessments of OECD member and non-member countries’ tax systems as well as concrete recommendations for tax policy reform. By identifying tailored tax policy reform options, the objective of the Reviews is to enhance the design of existing tax policies and to support the adoption of new reforms.
This report provides a comprehensive tax policy assessment of the taxes paid by individuals in Slovenia as well as tax reform recommendations. The report is divided into six chapters, with a summary of the main findings upfront, followed by more detailed recommendations at the end of chapters 3 to 6. Chapter 1 sets the scene for tax reform in Slovenia. Chapter 2 focuses on the labour market, social policy and tax policy related challenges. The ensuing chapters assess the financing of the social security system (Chapter 3), identify strategies to strengthen the design of personal income tax (Chapter 4), indirect taxes (Chapter 5), and the taxation of capital income at the individual level (Chapter 6).
This report is part of the OECD Tax Policy Reviews publication series. The Reviews are intended to provide independent, comprehensive and comparative assessments of OECD member and non-member countries’ tax systems as well as concrete recommendations for tax policy reform. By identifying tailored tax policy reform options, the objective of the Reviews is to enhance the design of existing tax policies and to support the adoption of new reforms. This report provides an assessment of Seychelles' tax system and recommendations for tax reform, with a focus on the business tax. Chapter 1 gives an overview of Seychelles' key economic and tax challenges. Chapter 2 provides a comprehensive assessment of Seychelles' business tax system and simulates the impact of different business tax reform scenarios, based on business taxpayer microdata. Chapter 3 focuses on improving the design of non-business taxes.
This report is part of the OECD Tax Policy Reviews publication series. The Reviews are intended to provide independent, comprehensive and comparative assessments of OECD member and non-member countries’ tax systems as well as concrete recommendations for tax policy reform. This report provides a comprehensive assessment of Lithuania’s tax and benefit system and recommendations for tax reform. It outlines the country's key economic and tax challenges and assesses the effects of taxation on employment. A special focus is given to the taxation of self-employed individuals.
This report is part of the OECD Tax Policy Reviews publication series. The Reviews are intended to provide independent, comprehensive and comparative assessments of OECD member and non-member countries’ tax systems as well as concrete recommendations for tax policy reform. By identifying tailored tax policy reform options, the objective of the Reviews is to enhance the design of existing tax policies and to support the adoption of new reforms. This report provides an assessment of Kazakhstan's tax system and recommendations for tax reform. Chapter 1 gives an overview of the main findings and Chapter 2 sets the scene for tax reform. Chapter 3 considers tax revenue trends and analysis of the tax mix. Chapter 4 examines equity issues in Kazakhstan and provides recommendations on the personal income tax, social security contributions and value added taxes. Chapter 5 focuses on tax competitiveness issues and provides recommendations on how to strengthen the design of both the corporate income tax and special tax regimes for SMEs.
This report is part of a new series of publications entitled OECD Tax Policy Reviews. These country reviewsare intended to provide independent, comprehensive and comparative assessments of OECD member and non-member countries’ tax systems from a tax policy perspective as well as concrete recommendations for tax policy reform. By benchmarking countries’ tax systems and identifying tailored tax policy reform options, the ultimate objective of the reviews is to enhance the design of existing tax policies and to support the adoption and implementation of tax policy reforms.
This first edition provides a comprehensive tax policy assessment of Costa Rica’s current tax system as well as tax policy reform recommendations. The report is divided into five chapters, starting with a general chapter providing an overview of key macroeconomic and tax revenue trends (Chapter 1), followed by an assessment of the main types of taxes of the Costa Rican tax system, including corporate income taxes (Chapter 2), personal income taxes and social security contributions (Chapter 3), the general sales tax (Chapter 4) and environmentally-related taxes (Chapter 5)
This report is part of the OECD Tax Policy Reviews publication series. The Reviews are intended to provide independent, comprehensive and comparative assessments of OECD member and non-member countries’ tax systems or zoom in on a specific tax policy topic. This report provides an in-depth assessment of Colombia’s tax expenditure reporting practices and makes specific recommendations as to how the measurement of tax expenditures and their reporting can be improved. In particular, the review introduces a benchmark for the corporate and personal income tax and the value-added tax and calculates revenue forgone from income tax expenditures.
This report is part of the OECD Tax Policy Reviews publication series. The Reviews are intended to provide independent, comprehensive and comparative assessments of OECD member and non-member countries’ tax systems. Drawing primarily on OECD Revenue Statistics data prior to the COVID-19 pandemic, the report examines the level, composition and evolution of the tax burden in Chile and explores whether tax revenues in Chile are converging to the levels raised in other OECD countries. The report also outlines a possible tax-to-GDP trajectory in Chile over the coming decade if Chile were to follow the path of countries from when they had a similar level of economic development.
This edition of the OECD Secretary-General's Report to Ministers outlines the main achievements of the OECD in 2020, notably the Organisation’s efforts to help manage the COVID-19 crisis and pave the way towards a stronger, more inclusive, resilient and green recovery. It describes the OECD’s work across major policy areas, with a focus on health, employment, inequalities, economics and tax, education, and the environment, among others. The report outlines the activities of the Secretary-General and his office, as well as those of OECD directorates, the Secretariats of Entities within the OECD family and OECD Social Partners.
The OECD works on finding evidence-based solutions to a range of social, economic and environmental challenges, promoting “Better Policies for Better Lives”. The OECD is one of the world’s largest and most trusted sources of comparable statistical data and research. The OECD serves as not only a pathfinder for new narratives and new initiatives at the global level, but also as a ‘do’ tank ready to support members and partners with our data, standards and evidence-based policy advice.
The OECD works on finding evidence-based solutions to a range of social, economic and environmental challenges, promoting “Better Policies for Better Lives”. The global spread of coronavirus in 2020 has made the commitment to this motto all the more relevant. This edition of the OECD Secretary-General's Report to Ministers outlines the main achievements of the OECD in 2019. It describes the OECD’s work on economics, employment, education, health, inequalities, the environment, tax and many other fields in the context of a rapidly changing world. It includes the activities of the Secretary-General and his office, as well as those of OECD directorates, agencies, special entities and advisory committees.
The OECD is one of the world’s largest and most trusted sources of comparable statistical data and research. It is also a unique forum and knowledge hub for exchange of experiences, best-practice sharing, and advice on public policies and global standard-setting. This year will mark the 60th anniversary of the Organisation, and this will be the opportunity to reflect on the past, and develop a vision for the future. More than ever, we need evidence-based policies geared towards building societies and economies that are more resilient, inclusive and sustainable.