OECD tax: 2009 edition of the "Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations"

The OECD released the 2009 edition of the "Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations" on 7 September 2009. The Guidelines discuss the application of the arm's length principle to cross-border transactions between associated enterprises. The OECD also released a draft discussion document that contains a proposed revision of chapters 1-3 of the Guidelines. The draft proposes to amend the hierarchy of transfer pricing methods, update the comparability analysis, provide additional guidance on the application of transactional profit methods and add three new annexes containing examples of the application of the transactional profit methods and a working capital adjustment.