The Resource Retroactive application of the OECD Transfer Pricing Guidelines for interpretation in transfer pricing issues

Retroactive application of the OECD Transfer Pricing Guidelines for interpretation in transfer pricing issues

Label
Retroactive application of the OECD Transfer Pricing Guidelines for interpretation in transfer pricing issues
Title
Retroactive application of the OECD Transfer Pricing Guidelines for interpretation in transfer pricing issues
Creator
Subject
Language
  • eng
  • eng
Summary
The position of soft obligations as legal sources is a continuously discussed topic in international law. As policy documents, guidelines and non-binding agreements often are regularly updated, the question of the applicability of different editions to various points in time may arise. The OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (OECD Guidelines) were revised most recently in July 2017, and these timing issues therefore appear in, for example, the undertaking of historical transfer pricing reviews and audits of years prior to the release of the updated OECD Guidelines. This article explores the arguments for using the new edition of the OECD Guidelines by comparison to an approach discussed in literature on finding guidance from different versions of the OECD Model Tax Convention (OECD Model) and its Commentary
Citation source
In: International transfer pricing journal. - Amsterdam. - Vol. 25 (2018), no. 6 ; p. 403-407
http://library.link/vocab/creatorName
Hagelin, J
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • OECD Transfer Pricing Guidelines
  • transfer pricing
  • retroactivity
  • treaty interpretation
Label
Retroactive application of the OECD Transfer Pricing Guidelines for interpretation in transfer pricing issues
Instantiates
Publication
Note
20190103
Other control number
itpj_2018_06_int_3.html
Label
Retroactive application of the OECD Transfer Pricing Guidelines for interpretation in transfer pricing issues
Publication
Note
20190103
Other control number
itpj_2018_06_int_3.html

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