OECD discussion draft on transfer pricing aspects of business restructurings

On 19th September 2008, the Organisation for Economic Cooperation and Development (OECD) published a lengthy discussion paper containing draft guidance on the application of transfer pricing rules to business restructurings (discusssion draft). It stresses the need to look at all the arrangements, including the substance of transactions and not just their legal form. Comments on the discussion draft are invited before 19 February 2009.
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