Arcotia Hatsidimitris - International Tax Dialogue

18 – 1. INTRODUCTION
Notes
1 Model Tax Convention on Income and on Capital (www.oecd.org/ctp/tt/mtc); United
Nations Model Double Taxation Convention between developed and developing countries
(http://www.un.org/esa/ffd/documents/DoubleTaxation.pdf)
2 Lanz, R. and S. Miroudot (2011), “Intra-Firm Trade: Patterns, Determinants and Policy
Implications”, OECD Trade Policy Working Papers, No. 114, OECD Publishing.
http://dx.doi.org/10.1787/5kg9p39lrwnn-en
3 Study into the Role of Tax Intermediaries: www.oecd.org/dataoecd/28/34/39882938.pdf;
Building Transparent Tax Compliance by Banks: www.oecd.org/ctp/ta/banks;
Framework for a Voluntary Code of Conduct for Revenue Bodies and Banks:
www.oecd.org/dataoecd/10/9/45989171.pdf; and Joint Audit Report and Joint Audit
Participants Guide: www.oecd.org/dataoecd/10/13/45988932.pdf (Report) and
www.oecd.org/dataoecd/10/11/45988962.pdf (Participants Guide).
4 Austria, Canada, Denmark, Finland, France, India, Ireland, Italy, South Africa, the
United Kingdom and the United States.
5 For the sake of clarity the term ‘audit’ refers only to fundamental challenges to the arm’s
length price. Countries were not asked to provide information about audits whose scope is
limited to ensuring that the legal requirements for documentation have been fulfilled. Some
countries refer to fundamental challenges to the arm’s length prices used as ‘enquiries.’ For
the sake of clarity the term audit or enquiry is used in the rest of this report.
6 In some countries the number of cases settled in any year is small and publication of the full
results could compromise taxpayer confidentiality as a result. That is why only summary
information has been included in this report.
7 A precise figure is difficult to calculate because countries have slightly different bases for
determining when a case commences and when it is concluded, some counting the time from
when the return is received and others from the point when a firm decision to enquire into a
transfer pricing risk has been taken.
DEALING EFFECTIVELY WITH THE CHALLENGES OF TRANSFER PRICING © OECD 2012