REPORT ON THE TRANSFER PRICING ASPECTS OF …

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ORGANISATION FOR ECONOMIC CO-OPERATION AND DEVELOPMENT REPORT ON THE TRANSFER PRICING ASPECTS OF BUSINESS RESTRUCTURINGS CHAPTER IX OF THE TRANSFER PRICING GUIDELINES 22 July 2010 CENTRE FOR TAX POLICY AND ADMINISTRATION FOREWORD This REPORT was approved by the Committee on Fiscal Affairs on 22 June 2010 and by the OECD Council on 22 July 2010. The Recommendation of the Council on the Determination of TRANSFER PRICING between Associated Enterprises [C(95)126/FINAL] was amended on 22 July 2010 to take account of the addition of the attached new Chapter IX and concomitant revision of Chapters I-III of the OECD TRANSFER PRICING Guidelines for Multinational Enterprises and Tax Administrations. 2 TABLE OF CONTENTS Chapter IX TRANSFER PRICING ASPECTS of Business Restructurings ........................................ .................... 4 Introduction.

organisation for economic co-operation and development report on the transfer pricing aspects of business restructurings chapter ix of the transfer pricing guidelines

  Transfer, Pricing, Transfer pricing