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)
“In other words, a democratic government is the only one in which those who vote for a tax can escape the obligation to pay it.”
—Alexis de Tocqueville (1805–1859)
“The great challenge which faces us is to assure that, in our society of big-ness, we do not strangle the voice of creativity, that the rules of the game do not come to overshadow its purpose, that the grand orchestration of society leaves ample room for the man who marches to the music of another drummer.”
—Hubert H. Humphrey (1911–1978)