TPG1979 Preface Paragraph 8

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The report covers in some detail some of the more important types of transfer which, in practice, take place between associated enterprises. It should be sa1a at the outset that some subjects have been treated in a way which may seem to be comparatively superficial and others have not been discussed at all. The reason for this is either that the report concentrates on the more pressing problems or that the topics are so case-oriented that satisfactory generalisation is not possible. Among topics omitted altogether from the report are certain types of transfers which seemed of lesser or less general importance – for example sales as distinct from transfers of the right to use patents and know-how, transfers of literary and artistic copyrights, transactions in real estate and transactions in securities such as shares and bonds. Also outside the scope of the present report, since the aim has been as far as possible to set out general principles, is any attempt to deal with special transfer pricing problems relating to particular industries or special types of enterprise. Finally no mention is made of the treatment of corresponding adjustments (as referred to in Article 9 (2) of the OECD Model Double Taxation Convention), which is a related problem but outside the scope of this report. However a common approach based on the considerations set out in this report should help to reduce the need for any such corresponding adjustment.






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