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The increased speed and mobility of business activities and cross-border transactions resulting from internet usage has particular implications for applying transfer pricing methods and for taxing business profits. This book presents a two-part look at existing OECD positions on these issues. Part I of this edition analyses e-commerce transfer pricing in the context of four business models: automated electronic transactions; online auctions for customer-to-customer and business-to-business sales; subsidiary-to-parent web hosting arrangements; and computerised transactions for airline reservations. The OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations provide guidance on the application of the arm’s length. | OECD Tax Policy Studies E-commerce Transfer Pricing and Business Profits Taxation No. 10 OECD Tax Policy Studies E-commerce Transfer Pricing and Business Profits Taxation No. 10 OECD ORGANISATION FOR ECONOMIC CO-OPERATION AND DEVELOPMENT ORGANISATION FOR ECONOMIC CO-OPERATION AND DEVELOPMENT The OECD is a unique forum where the governments of 30 democracies work together to address the economic social and environmental challenges of globalisation. The OECD is also at the forefront of efforts to understand and to help governments respond to new developments and concerns such as corporate governance the information economy and the challenges of an ageing population. The Organisation provides a setting where governments can compare policy experiences seek answers to common problems identify good practice and work to co-ordinate domestic and international policies. The OECD member countties are Australia Austria Belgium Canada the Czech Republic Denmark Finland France Germany Greece Hungary Iceland Ireland Italy Japan Korea Luxembourg Mexico the Netherlands New Zealand Norway Poland Portugal the Slovak Republic Spain Sweden Switzerland Turkey the United Kingdom and the United States. The Commission of the European Communities takes part in the work of the OECD. OECD Publishing disseminates widely the results of the Organisation s statistics gathering and research on economic social and environmental issues as well as the conventions guidelines and standards agreed by its members. o J This work is published on the responsibility of the Secretary-General of the OECD. The opinions expressed and arguments employed herein do not necessarily reflect the official views of the Organisation or of the governments of its member countries. Also available in French under the title Commerce électronique Les prix de transfer et les impôts sur les profits commerciaux N 10 OECD 2005 No reproduction copy transmission or translation of this publication may be made without written .
