Le premier tome d'une nouvelle saga qui promet d'être aussi addictive que Le Clan des Otori. On retrouve avec un plaisir inégalé l'univers de Lian Hearn, son japon médiéval pétri de magie, son ambiance aussi éthérée que pesante, ses nombreux personnages attachants, ses luttes de pouvoir...
This 2009 edition of Transfer Pricing Guidelines has now been superceded by a more recent edition.
OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrationsprovides 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.
TheOECD Transfer Pricing Guidelinesclarifies 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 theModel 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 (Lien -> http://www.oecd.org/ctp/memap)) have also been included and the foreword and preface have been updated.