OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations provides guidance on the application of the "arm's length principle" for valuation for tax purposes of cross-border transactions between associated enterprises. In a global economy where multinational enterprises (MNEs) play a prominent role, governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdiction and that the tax base reported by MNEs in their country reflects the economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation that may result from a dispute between two countries on the determination of the arm’s length remuneration for their cross-border transactions with associated enterprises.
The OECD Transfer Pricing Guidelines clarifies these issues and were originally approved by the OECD Council in 1995. In this 2009 edition, some amendments have been made to Chapter IV, primarily to reflect the adoption, in the 2008 update of the Model Tax Convention, of a new paragraph 5 of Article 25 dealing with arbitration, and of changes to the Commentary on Article 25 on mutual agreement procedures to resolve cross-border tax disputes. References to good practices identified in the online Manual for Effective Mutual Agreement Procedures (www.oecd.org/ctp/memap) have also been included and the foreword and preface have been updated.
The publication outlines a number of innovative approaches to enable governments to better manage the risks involved with marketed tax schemes and tailor-made arrangements. To improve compliance, tax administrations could consider changing the structure of their operations to focus resources effectively, for example, through the creation of a dedicated HNWI unit. Other recommendations include creating the appropriate legal framework, exploring forms of co-operative compliance and engaging more in international co-operation, at both the strategic and operational level.
Part I of this edition analyses e-commerce transfer pricing in the context of four business models: automated electronic transactions; online auctions for customer-to-customer and business-to-business sales; subsidiary-to-parent web hosting arrangements; and computerised transactions for airline reservations. The OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations provide guidance on the application of the arm’s length principle to transfer pricing methods.Given the fact patterns of the four business models, Part I assesses how appropriate this guidance is to the issues raised by e-commerce.
Part II of this edition examines the current OECD Model Tax Convention treaty rules for taxing business profits. It studies whether the existing rules are capable of dealing with the new reality of e-commerce in a fair and effective manner and whether it could be possible to find better alternatives.
This report offers policy insights and stimulates new research to complement and further develop the recent OECD Teaching and Learning International Survey (TALIS) and the upcoming PISA 2012 assessment, which will again focus on mathematics. In addition, this report may be of interest to teachers, educators and officials within national and local educational authorities responsible for the professional development of teachers or for programme development, as well as members of school boards and parent advisory bodies.
The report offers a comprehensive overview of the rapidly changing phenomenon of Open Educational Resources and the challenges it poses for higher education. It examines reasons for individuals and institutions to share resources for free, and looks at copyright issues, sustainability and business models as well as policy implications. It will be of particular interest to those involved in e-learning or strategic decision making within higher education, to researchers and to students of new technologies.
PISA Computer-Based Assessment of Student Skills in Science describes how the 2006 survey was administered, presents 15-year-olds’ achievement scores in science and explains the impact of information communication technologies on both males’ and females’ science skills. While males outperformed females on the computer-based test in all three countries, females in Iceland and males in Denmark performed better than their counterparts on the paper-and-pencil test. The evidence shows that, overall, males are more confident and use computers more frequently. While females tend to use the Internet more for social networking activities, males tend to browse the Internet, play games and download software.
Readers will also learn how students reacted to the electronic questionnaire and how it compared with pencil-and-paper tests. In general, there were no group differences across test methods buts students enjoyed the computer-based test more than the paper-and-pencil test.
This new publication is a product of the OECD-Eurostat Entrepreneurship Indicators Programme, which is a long-term programme of internationally-comparable policy-relevant entrepreneurship statistics. The work involves developing standard definitions and concepts and engaging countries and international Agencies in the collection of data. An international group of statisticians and analysts provides guidance to the Programme that benefits from sponsorship by the Ewing Marion Kauffman Foundation in the United States.
Data are provided for all OECD member countries (including area totals), and for Brazil, China, India, Indonesia, the Russian Federation and South Africa. For each indicator, there is a two-page spread: a text page includes a short introduction followed by a detailed definition of the indicator, comments on comparability of the data, an assessment of long-term trends related to the indicator and a list of references for further information on the indicator; the second page contains a table and a graph providing, at a glance, the key message conveyed by the data. Each indicator includes "StatLinks" which allow readers to download the corresponding data.
OECD Countries covered include Australia, Austria, Belgium, Canada, Chile,Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Israel, Italy, Japan, Korea, Luxembourg, Mexico, Netherlands, New Zealand, Poland, Portugal, Slovak Republic, Slovenia, Spain, Sweden, Switzerland, Turkey, the United Kingdom, and the United States. Non-OECD countries covered include Brazil, China, India, Indonesia, Russia, and South Africa.
Topics covered include population and migration; production and productivity; household income, wealth and debt; globalisation, trade and foreign direct investment (FDI); prices, interest rates and exchange rates; energy and transportation; labour, employment and unemployment; science and technology including research and development (R&D) and the Information and Communications Technology (ICT) sector; environment including natural resoures, water,and air and climate; education resources and outcomes; government expenditures, debt, revenues, taxes, agricultural support and foreign aid; and health status, risk and resources.
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