Examples of OECD Transfer Pricing Guidelines in a sentence
See the Instructions for Schedule M-3 (Form 1120-F) for the reporting of book-tax differences in Parts II and III of that schedule under a treaty-based return position pursuant to OECD Transfer Pricing Guidelines.
The implementation of this standard in the section 482 regulations is in accordance with the general principles of paragraph 1 of Article 9 of the Convention, as interpreted by the OECD Transfer Pricing Guidelines.
Patients and methodsPATIENTSWe studied 30 consecutive patients with clinically definite multiple sclerosis17 (18 women and 12 men, mean age 38.4 years, range 23–57 years).
Second, regarding the second step of that analysis, it should be borne in mind that the Authorised OECD Approach refers to the OECD Transfer Pricing Guidelines.
Reference if any to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations in domestic legislation or regulations.
The parties disagree, in essence, as to the extent to which the Commission was entitled to rely, for the purposes of its subsidiary line of reasoning, on the arm’s length principle, as laid down in the OECD Transfer Pricing Guidelines, to which the Authorised OECD Approach refers.
The RRV and KSHV genomes exhibit a high degree of co-linearity of, with 67 of 79 ORFs sharing some level of homology (reviewed in(382) .
In addition, according to paragraph 2.93 of the OECD Transfer Pricing Guidelines, to which the Commission refers in recital 343 of the contested decision, ‘in applying a cost-based [TNMM], fully loaded costs are often used’.
That IP may therefore be regarded, in the present instance, as a unique asset for the purposes of the OECD Transfer Pricing Guidelines.
That approach, which was endorsed in principle by the High Court, involved adjustments equivalent to those proposed on the basis of the arm’s length principle, in particular in the OECD Transfer Pricing Guidelines.