دانلود کتاب Oecd Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017

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Foreword
Table of Contents
Preface
Abbreviations and Acronyms
Glossary
Chapter I. The Arm\'s Length Principle
Introduction
Statement of the arm’s length principle
A non-arm’s-length approach: global formulary apportionment
Guidance for applying the arm’s length principle
Chapter II. Transfer Pricing Methods
Part I: Selection of the transfer pricing method
Selection of the most appropriate transfer pricing method to the circumstances of the case
Use of more than one method
Part II: Traditional transaction methods
Introduction
Comparable uncontrolled price method
Resale price method
Cost plus method
Part III: Transactional profit methods
Introduction
Transactional net margin method
Transactional profit split method
Conclusions on transactional profit methods
2.114
Chapter III. Comparability Analysis
Performing a comparability analysis
Timing issues in comparability
Compliance issues
Chapter IV. Administrative Approaches to Avoiding and Resolving Transfer Pricing Disputes
Introduction
Transfer pricing compliance practices
Corresponding adjustments and the mutual agreement procedure: Articles 9 and 25 of the OECD Model Tax Convention
Simultaneous tax examinations
Safe harbours
Advance pricing arrangements
Arbitration
Chapter V. Documentation
Introduction
Objectives of transfer pricing documentation requirements
A three-tiered approach to transfer pricing documentation
Compliance issues
Implementation
Chapter VI. Special Considerations for Intangibles
Identifying intangibles
Ownership of intangibles and transactions involving the development, enhancement, maintenance, protection and exploitation of intangibles
Transactions involving the use or transfer of intangibles
Supplemental guidance for determining arm’s length conditions in cases involving intangibles
6.78
Chapter VII. Special Considerations for Intra-Group Services
Introduction
Main issues
Some examples of intra-group services
Low value-adding intra-group services
Chapter VIII. Cost Contribution Arrangements
Introduction
Concept of a CCA
Applying the arm’s length principle
CCA entry, withdrawal or termination
Recommendations for structuring and documenting CCAs
Chapter IX. Transfer Pricing Aspects of Business Restructurings
Introduction
Part I: Arm’s length compensation for the restructuring itself
Introduction
Understanding the restructuring itself
Recognition of the accurately delineated transactions that comprise the business restructuring
Reallocation of profit potential as a result of a business restructuring
Transfer of something of value (e.g. an asset or an ongoing concern)
Indemnification of the restructured entity for the termination or substantial renegotiation of existing arrangements
Part II: Remuneration of post-restructuring controlled transactions
Business restructurings versus “structuring”
Application to business restructuring situations: selection and application of a transfer pricing method for the post-restructuring controlled transactions
Relationship between compensation for the restructuring and post-restructuring remuneration
Comparing the pre- and post-restructuring situations
Location savings
List of Annexes
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
Sample Memorandum of Understanding on Low Risk Manufacturing Services
Sample Memorandum of Understanding on Low Risk Distribution Services
Sample Memorandum of Understanding on Low Risk Research and Development Services
Annex II to Chapter IV. Guidelines for Conducting Advance Pricing Arrangements under the Mutual Agreement Procedure (MAP APAs)
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 IV to Chapter V. Country-by-Country Reporting Implementation Package
Model legislation related to Country-by-Country Reporting
Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports
Annex to the Agreement – Confidentiality and Data Safeguards Questionnaire
Competent Authority Agreement on the Exchange of Country-by-Country Reports on the basis of a Double Tax Convention (“DTC CAA”)
Competent Authority Agreement on the Exchange of Country-by-Country Reports on the basis of a Tax Information Exchange Agreement (“TIEA CAA”)
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