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OECD Transfer Pricing Guidelines as a quasi source of law in a post-BEPS world legislative and judicial developments from a Polish perspective Bogumil Brzezinski, Krzysztof Lasinski-Sulecki and Wojciech Morawski Electrónico

By: Brzezinski, Bogumil.
Contributor(s): Lasinski Sulecki, Krzysztof | Morawski, Wojciech.
Material type: ArticleArticlePublisher: 2020Subject(s): PRECIOS DE TRANSFERENCIA | EMPRESAS MULTINACIONALES | DIRECTRICES | ORGANIZACION DE COOPERACION Y DESARROLLO ECONOMICO | POLONIA In: International Transfer Pricing Journal v. 27, n. 3, 2020 Summary: The OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations are of the utmost importance in the sphere of transfer pricing. Unlike article 9 of the OECD Model, which is rather general in wording, the OECD Transfer Pricing Guidelines offer a detailed guidance on transfer pricing methodology. The significance of the OECD Transfer Pricing Guidelines became even more noticeable when the BEPS Project was completed, because numerous changes to the global transfer pricing regime were envisaged in the amended guidelines and not in the text of the OECD Model itself. The aim of this article is to analyse the status of the OECD Transfer Pricing Guidelines in international and Polish domestic law, as well as current practice of their application.
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Resumen.

The OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations are of the utmost importance in the sphere of transfer pricing. Unlike article 9 of the OECD Model, which is rather general in wording, the OECD Transfer Pricing Guidelines offer a detailed guidance on transfer pricing methodology. The significance of the OECD Transfer Pricing Guidelines became even more noticeable when the BEPS Project was completed, because numerous changes to the global transfer pricing regime were envisaged in the amended guidelines and not in the text of the OECD Model itself. The aim of this article is to analyse the status of the OECD Transfer Pricing Guidelines in international and Polish domestic law, as well as current practice of their application.

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