TPG1979 Chapter I Paragraph 30

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It happens frequently when transactions with an associated enterprise take place over frontiers that the tax authorities need information concerning the associate in the other country or possibly some other associate in order to be able to determine the appropriate taxable profit in their own country. Often the tax authorities will not have possession of this information. In this context it is appropriate and may be helpful to refer to the OECD Guidelines for Multinational Enterprises which have been promulgated by Member Governments and, in particular, to the first Guideline on taxation and the Guideline on disclosure of information which are reproduced below.






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