051c. Transfer Pricing - Where We Stand - The 1995 OECD Guidelines

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INDEX

1.1 OECD: Confrontation And Compromise
1.2 OECD: Selected Issues
    General Tenor
    Transactional Profit Methods
    Arm's Length Principle
    Choice Of Method
    Transfer Price Methods
    Arm's Length Range
    Market Entry, Defence, And Expansion Strategies
    Intangible Assets
    Intra-Group Services
    Procedural Matters

THE 1995 OECD GUIDELINES

1.1 OECD: Confrontation And Compromise

The deliberations leading up to publication of the first five chapters of the OECD Guidelines in July 1995 were difficult and at times heated. They centred around the issues posed by the new American transfer pricing concepts discussed above. The most contentious points were the two new profit-oriented transfer pricing methods introduced in the U.S. regulations under section 482 IRC. Certain countries,