OECD Specific Tax Rules
OECD guidelines are voluntary for member nations. Some nations have adopted the guidelines almost unchanged. Terminology may vary between adopting nations, and may vary from that used above.
OECD guidelines give priority to transactional methods, described as the “most direct way” to establish comparability. The Transactional Net Margin Method and Profit Split methods are used either as methods of last resort or where traditional transactional methods cannot be reliably applied. CUP is not given priority among transactional methods in OECD guidelines. The Guidelines state, "It may be difficult to find a transaction between independent enterprises that is similar enough to a controlled transaction such that no differences have a material effect on price." Thus, adjustments are often required to either tested prices or uncontrolled process.
Read more about this topic: Transfer Pricing
Famous quotes containing the words specific, tax and/or rules:
“In effect, to follow, not to force the public inclination; to give a direction, a form, a technical dress, and a specific sanction, to the general sense of the community, is the true end of legislature.”
—Edmund Burke (1729–1797)
“I find nothing healthful or exalting in the smooth conventions of society. I do not like the close air of saloons. I begin to suspect myself to be a prisoner, though treated with all this courtesy and luxury. I pay a destructive tax in my conformity.”
—Ralph Waldo Emerson (1803–1882)
“The five kings count the dead but do not soften
The crusted wound nor stroke the brow;
A hand rules pity as a hand rules heaven;
Hands have no tears to flow.”
—Dylan Thomas (1914–1953)