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:
“I was asking for something specific and perfect for my city,
Whereupon lo! upsprang the aboriginal name.
Now I see what there is in a name, a word, liquid, sane, unruly,
musical, self-sufficient,
I see that the word of my city is that word from of old,
Because I see that word nested in nests of water-bays, superb,
Rich, hemm’d thick all around with sailships and steamships, an
island sixteen miles long, solid-founded,”
—Walt Whitman (1819–1892)
“Rumble thy bellyful! Spit, fire! Spout, rain!
Nor rain, wind, thunder, fire are my daughters.
I tax you not, you elements, with unkindness;
I never gave you kingdom, called you children.”
—William Shakespeare (1564–1616)
“Playing games with agreed upon rules helps children learn to live by rules, establish the delicate balance between competition and cooperation, between fair play and justice and exploitation and abuse of these for personal gain. It helps them learn to manage the warmth of winning and the hurt of losing; it helps them to believe that there will be another chance to win the next time.”
—James P. Comer (20th century)