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Transfer Pricing and Treaties

Lisa Casley of PricewaterhouseCoopers LLP considers the status of transfer pricing and treaties in the context of a changing world
On 21 and 22 September 2009 the OECD held a conference entitled 'Transfer pricing and treaties in a changing world'. Almost 700 transfer pricing and treaty experts from more than 90 governments the private sector non-governmental organisations (NGOs) academia and international organisations gathered in Paris for the event.
At last year's OECD conference participants overwhelmingly voted the adoption in 1995 of the OECD's 'Transfer pricing guidelines for multinational enterprises and tax administrations' (the OECD Guidelines) as the most important tax treaty development (besides the Model Tax Convention itself) of the past 50 years. So why is transfer pricing so high on everyone's agenda?
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