Precios de tranferencia

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OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations
22 JULY 2010

ORGANISATION FOR ECONOMIC CO-OPERATION AND DEVELOPMENT
The OECD is a unique forum where governments work together to address the economic, social and environmental challenges of globalisation. The OECD is also at the forefront of efforts to understand and to help governments respond to newdevelopments and concerns, such as corporate governance, the information economy and the challenges of an ageing population. The Organisation provides a setting where governments can compare policy experiences, seek answers to common problems, identify good practice and work to co-ordinate domestic and international policies. The OECD member countries are: Australia, Austria, Belgium, Canada, Chile,the Czech Republic, Denmark, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Japan, Korea, Luxembourg, Mexico, the Netherlands, New Zealand, Norway, Poland, Portugal, the Slovak Republic, Slovenia, Spain, Sweden, Switzerland, Turkey, the United Kingdom and the United States. The Commission of the European Communities takes part in the work of the OECD. OECD Publishingdisseminates widely the results of the Organisation’s statistics gathering and research on economic, social and environmental issues, as well as the conventions, guidelines and standards agreed by its members.

ISBN 978-92-64-09033-0 (print) ISBN 978-92-64-09018-7 (PDF)

Also available in French: Principes de l'OCDE applicables en matière de prix de transfert à l'intention des entreprisesmultinationales et des administrations fiscales

Corrigenda to OECD publications may be found on line at: www.oecd.org/publishing/corrigenda.

© OECD 2010
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NEW GUIDELINES FOR NEW REALITIES

New Guidelines for New Realities
A view from KPMG’s team of transfer pricing professionals*
On July 22, 2010, the OECD released a new edition of transfer pricing guidelines that (i) updated prior guidance in Chapters I – III, and (ii) provided new guidance on the transfer pricing issues presented in the context of businessrestructuring. These new Guidelines represent the results of several years of intensive work on the part of the OECD exploring issues related to comparability, the use of transactional profits methods, and business restructuring. Perhaps the most important outcome of this work is a strong re-affirmation that the pricing of transactions among associated enterprises should be based on the arm’s-lengthprinciple, i.e. that the pricing should reflect the conditions that would have been agreed to had the transaction taken place between comparable unrelated entities. Thus, the goal of the OECD Transfer Pricing Guidelines remains the same, even though the detailed guidance on how to reach this goal has been updated in several important respects. Another welcome development is that the new Guidelinesreaffirm, as was the case in 1995, that tax authorities should respect the transaction actually undertaken by the taxpayer in all but exceptional circumstances, which are defined in the new Guidelines as “rare” or “unusual.” Such exceptional cases are defined as situations in which (i) the substance of a transaction differs from its form or (ii) the arrangements made in relation to the transaction,...
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