Contents:
Foreword
Preface
Abbreviations and Acronyms
Glossary
The Arm's Length Principle
Transfer Pricing Methods
Comparability Analysis
Administrative Approaches to Avoiding and Resolving Transfer Pricing Disputes
Documentation
Special Considerations for Intangibles
Special Considerations for Intra-Group Services
Cost Contribution Arrangements
Transfer Pricing Aspects of Business Restructurings
Annex to the OECD Transfer Pricing Guidelines
Annex I to Chapter II. Sensitivity of Gross and Net Profit Indicators
Annex II to Chapter II. Example to Illustrate the Application of the Residual Profit Split Method
Annex III to Chapter II. lllustration of Different Measures of Profits When Applying a Transactional Profit Split Method
Annex to Chapter III. Example of a Working Capital Adjustment
Annex I to Chapter IV. Sample Memoranda of Understanding for Competent Authorities to Establish Bilateral Safe Harbours
Annex II to Chapter IV. Guidelines for Conducting Advance Pricing Arrangements under the Mutual Agreement Procedure (MAP As)
Annex I to Chapter V. Transfer Pricing Documentation – Master file
Annex II to Chapter V. Transfer Pricing Documentation – Local file
Annex III to Chapter V. Transfer Pricing Documentation – Country-by-Country Report
Annex to Chapter VI. Examples to Illustrate the Guidance on Intangibles
Annex to Chapter VIII. Examples to Illustrate the Guidance on Cost Contribution Arrangements
Appendix. Recommendation of the Council on the Determination of Transfer Pricing between Associated Enterprises C(95)126/Final, as amended