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OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017

image of OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017

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.

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Annex II to Chapter II. Example to Illustrate the Application of the Residual Profit Split Method

See Chapter II, Part III, Section C of these Guidelines for general guidance on the application of the profit split method. The adjustments and assumptions about arm’s length arrangements in the examples that follow are intended for illustrative purposes only and should not be taken as prescribing adjustments and arm’s length arrangements in actual cases or particular industries. While they seek to demonstrate the principles of the Sections of the Guidelines to which they refer, those principles must be applied in each case according to the specific facts and circumstances of that case.

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