OECD Transfer Pricing Guidelines definition

OECD Transfer Pricing Guidelines means the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022, endorsed by the OECD Council pursuant to the OECD Council Recommendation of the Council on the Determination of Transfer Pricing between Associated Enterprises [C(95)126/Final], and as amended in January 20, 2022 and included in Annex I, and any further amendments to these OECD Transfer Pricing Guidelines that the Union approved in the context of the OECD Committee on Fiscal Affairs via the adoption of a Union position under 218(9) TFEU;
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OECD Transfer Pricing Guidelines means the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022, endorsed
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OECD Transfer Pricing Guidelines means the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022, endorsed by the OECD Council pursuant to the OECD Council Recommendation of the Council on the Determination of Transfer Pricing between Associated Enterprises [C(95)126/Final], and as amended in January 20, 2022 and included in Annex I; The Commission shall be empowered to adopt delegated acts, in accordance with Article 18, in order to incorporate any further amendments of these OECD Transfer Pricing Guidelines into this Directive;
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Examples of OECD Transfer Pricing Guidelines in a sentence

  • 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.

  • These policies are consistent with 2017 OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.

  • Both the OECD Transfer Pricing Guidelines and the U.S. Internal Revenue Code (section 1.482-7) provide a set of rules on how to enter into Cost Sharing Agreements at arm’s length.

  • 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 principles of the OECD Transfer Pricing Guidelines will apply for purposes of determining the profits attributable to a permanent establishment, taking into account the different economic and legal circumstances of a single entity.

  • The OECD defines secondary adjustments in the Glossary of the OECD Transfer Pricing Guidelines (TPG) as "an adjustment that arises from imposing tax on a secondary transaction in transfer pricing cases", and a secondary transaction as a constructive transaction that some States assert under their domestic transfer pricing legislation after having proposed a primary adjustment in order to make the actual allocation of profits consistent with the primary adjustment.

  • This treaty-based reporting is permitted only if the applicable income tax treaty and accompanying documents (such as Exchange of Notes) expressly provide that attribution of business profits to aU.S. permanent establishment is determined under OECD Transfer Pricing Guidelines applied by analogy.

  • Do not complete Schedule H if the corporation files Form 1120-F pursuant to an income tax treaty to report business profits attributable to a U.S. permanent establishment and applies OECD Transfer Pricing Guidelines in lieu of the ECI and expense allocation and apportionment rules of section 882(c) and Regulations sections 1.861-8 and1.861-17 and Temporary Regulations section 1.861-8T.

  • These guidelines are largely based on the arm‟s length methodologies as set out under the Organisation for Economic Co- operation and Development (OECD) Transfer Pricing Guidelines.

  • According to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, “ordinarily, the secondary transactions will take the form of constructive dividends, constructive equity contributions, or constructive loans.


More Definitions of OECD Transfer Pricing Guidelines

OECD Transfer Pricing Guidelines means the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022, endorsed by the OECD Council pursuant to the OECD Council Recommendation of the Council on the Determination of Transfer Pricing between Associated Enterprises [C(95)126/Final], and as amended in January 20, 2022 and
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OECD Transfer Pricing Guidelines means the latest version of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations as of the entry into force of this Directive and any further amendments to these OECD Transfer Pricing Guidelines that the Union approved in the context of the OECD Committee on Fiscal Affairs via the adoption of a Union
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Related to OECD Transfer Pricing Guidelines

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  • Local Exchange Routing Guide (LERG means the iconectiv Reference document used by Telecommunications Carriers to identify NPA-NXX routing and homing information as well as Network element and equipment designations.

  • Local Exchange Routing Guide (LERG) is a Telcordia Reference document used by Telecommunications Carriers to identify NPA-NXX routing and homing information as well as Network element and equipment designations.

  • Underwriting Guidelines The underwriting guidelines of the Seller, a copy of which is attached as an exhibit to the related Assignment and Conveyance.

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  • 2%/25% Guidelines has the meaning set forth in Section 13.

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  • Xxxxxx Xxx Guides The Xxxxxx Xxx Xxxxxxx' Guide and the Xxxxxx Xxx Servicers' Guide and all amendments or additions thereto.

  • Xxxxxx Xxx Guide means the Xxxxxx Mae MBS Selling and Servicing Guide, as such Guide may hereafter from time to time be amended.

  • ECB €STR Guideline means Guideline (EU) 2019/1265 of the European Central Bank of 10 July 2019 on the euro short-term rate (€STR) (ECB/2019/19), as amended from time to time;

  • EU Bail-In Legislation Schedule means the EU Bail-In Legislation Schedule published by the Loan Market Association (or any successor person), as in effect from time to time.

  • Branding Guidance means the Authority's guidance in relation to the use of branding;

  • User Guide means such user guide or document issued or prescribed by us, through any medium, setting out instructions on the use of the EB Services;

  • Federal poverty guidelines means the poverty guidelines published annually in the federal register by the United States department of health and human services under its authority to revise the poverty line under section 673(2) of subtitle B of title VI of the omnibus budget reconciliation act of 1981, 42 USC 9902.

  • Program Requirements means certain minimum program entry requirements as well as ongoing program requirements, to be fulfilled by Partner, some of which are general PartnerEdge requirements, some of which are specific for the “Sell Engagement” and some of which are specific for the different “Cloud” Product Families, including, without limitation payment of the Program Fee(s), meeting certain minimum annual revenue requirements, upholding a Sell Authorization for at least one “Cloud” Product Family and other requirements as set out in detail in the PartnerEdge Program Guide and the RSPI.

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  • SEBI Listing Regulations means SEBI (Listing Obligation and Disclosure Requirements) Regulations, 2015, as amended

  • Implementation Schedule means the Implementation Schedule in Section VII of the tendering documents.

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  • Program Guide The Residential Funding Seller Guide for mortgage collateral sellers that participate in Residential Funding's standard mortgage programs, and Residential Funding's Servicing Guide and any other subservicing arrangements which Residential Funding has arranged to accommodate the servicing of the Mortgage Loans.

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  • Fixed guideway means a public transit facility that uses and occupies: