The OECD is working on possibly expanding the types of tax adjustments that should be subject to mutual agreement procedures in the organization’s model treaty, an official said Tuesday.
A new project at the organization is looking to address instances where tax authorities block a company’s access to a MAP—a dispute resolution process—because the dispute at issue isn’t specifically identified as a transfer pricing issue, and to clarify what is covered under Article 9 of the OECD’s model tax treaty.
Article 9 governs the treatment of “associated enterprises,” or related companies, and establishes the arms-length principle for transfer pricing—the rule ...