The OECD announced the approval of the 2010 versions of its model tax convention transfer pricing guidelines and report on the attribution of profits to permanent establishments.
The update to the model tax convention includes a new article 7 on business profits. The revised transfer pricing guidelines contain more detailed guidance on how to perform comparability analyses in practice the OECD said. They also include new guidance on how to select the most appropriate transfer pricing method to the circumstances of the case and on how to apply in practice two OECD-approved transfer pricing methods known as ‘transactional profit methods’ namely the transactional net margin method and the transactional profit split method.
The OECD invited comments by 15 September on the scoping of a future project on the transfer pricing aspects of intangibles. Comments should be sent Jeffrey Owens Director Centre for Tax Policy...
