Tag: OECD Handbook on Transfer Pricing Risk Assessment

TPG2022 Chapter V paragraph 5.10

Effective risk identification and assessment constitute an essential early stage in the process of selecting appropriate cases for transfer pricing audits or enquiries and in focusing such audits on the most important issues. Because tax administrations operate with limited resources, it is important for them to accurately evaluate, at the very outset of a possible audit, whether a taxpayer’s transfer pricing arrangements warrant in-depth review and a commitment of significant tax enforcement resources. Particularly with regard to transfer pricing issues (which generally are complex and fact-intensive), effective risk assessment becomes an essential prerequisite for a focused and resource-efficient audit. The OECD Forum on Tax Administration has developed a number of tools to assist tax administrations in conducting such risk assessments ...
OECD Handbook on Transfer Pricing Risk Assessment, Risk assessment, Transfer pricing documentation

TPG2017 Chapter V paragraph 5.10

Effective risk identification and assessment constitute an essential early stage in the process of selecting appropriate cases for transfer pricing audits or enquiries and in focusing such audits on the most important issues. Because tax administrations operate with limited resources, it is important for them to accurately evaluate, at the very outset of a possible audit, whether a taxpayer’s transfer pricing arrangements warrant in-depth review and a commitment of significant tax enforcement resources. Particularly with regard to transfer pricing issues (which generally are complex and fact-intensive), effective risk assessment becomes an essential prerequisite for a focused and resource-efficient audit. The OECD Handbook on Transfer Pricing Risk Assessment is a useful tool to consider in conducting such risk assessments ...
OECD Handbook on Transfer Pricing Risk Assessment, Risk assessment, Transfer pricing documentation

April 2013: Draft Handbook on Transfer Pricing Risk Assessment

The 2013 Draft Handbook on Transfer Pricing Risk Assessment is a detailed, practical resource that countries can follow in developing their own risk assessment approaches. The handbook supplements useful materials already available with respect to transfer pricing risk assessment. The OECD Forum on Tax Administration published a report entitled “Dealing Effectively with the Challenges of Transfer Pricing†in January 2012. One chapter of that report also addresses transfer pricing risk assessment ...
Business restructuring, CCA/CSA, Excessive debt, Information in foreign companies, Low tax jurisdiction, Management fee, OECD Handbook on Transfer Pricing Risk Assessment, Procurement, Publicly available information, Risk assessment, Royalty and License payments, Supplemental guidance, Tax avoidance, Tax avoidance arrangements, Transfers of intangibles