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:
“Self-esteem and self-contempt have specific odors; they can be smelled.”
—Eric Hoffer (1902–1983)
“In 1845 he built himself a small framed house on the shores of Walden Pond, and lived there two years alone, a life of labor and study. This action was quite native and fit for him. No one who knew him would tax him with affectation. He was more unlike his neighbors in his thought than in his action. As soon as he had exhausted himself that advantages of his solitude, he abandoned it.”
—Ralph Waldo Emerson (1803–1882)
“Children can’t make their own rules and no child is happy without them. The great need of the young is for authority that protects them against the consequences of their own primitive passions and their lack of experience, that provides with guides for everyday behavior and that builds some solid ground they can stand on for the future.”
—Leontine Young (20th century)