The two main OECD tax publications are updated
The OECD has published a 2010 update to the Model Tax Convention which contains an amended version of Article 7 dealing with business profits and the profits attributable to a permanent establishment. There are also revisions to the Commentaries on a number of the Articles in the Model plus a number of observations, reservations and positions re the Commentary which brings to 31 the number of non OECD countries that have set out positions etc.
A revised condensed version of the OECD Model that will include the changes resulting from the update will be published in September 2010.
OECD is also publishing a revision to the Transfer Pricing Guidelines and this is the first major revision since the Guidelines were first published in 1995. The publication will be available for sale from September 2010.
Chapters 1 to 3 of the Guidelines have been updated to cover the issue as to how you choose the most appropriate transfer pricing method in any particular case, the practical application of transactional profit methods (the transactional net margin method and the profit split method) and the performance of comparability analyses.
There is also a new Chapter 9 in the Guidelines which incorporates the results of the OECD consultation on Business Restructurings to which ICAEW contributed.
On 22 July 2010 OECD published a response document to the various responses they had received to the original September 2008 consultation document on Business Restructuring.