Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, Discussion Draft of Part I

The establishment for tax purposes of appropriate transfer pricing - the pricing at which an enterprises transfers physical goods or intangible property or provides services to associated enterprises - figures among the most difficult issues in international taxation. It determines the income and expenses, and therefore the profits, of associated enterprises in different tax jurisdictions. OECD governments recognize that internationally agreed guidelines on transfer pricing are necessary to minimize tax barriers to international trade and investment. This Discussion Draft provides the text of Part I of a report which, if finalized, is intended to set forth internationally agreed transfer pricing guidelines.