On June 6, 2012, the Organisation for Economic Co-operation and Development (OECD) released a discussion draft on potentially updating the provisions of Article 6 of the OECD Transfer Pricing Guidelines (Guidelines). The draft was released by Working Party No. 6 for purposes of comment, and does not reflect a consensus of the member countries.
The draft contains two principal elements: (1) a proposed revision of Chapter 6 of the Guidelines and (2) a proposed revision of examples in the Annex to Chapter 6.
A summary of the content of the 2012 draft follows.
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