Comment on OECD Transactional Profit Issues50208

ABCD KPMG LLP Telephone 202 533 3800 2001 M Street, NW Washington, DC 20036-3310 To Jeffrey Owens Date May 2, 2008 Director of the OECD Centre for Tax Policy and Administration From KPMG’s Global Transfer Pricing Services, contact Clark Ref Comments on OECD Issues Notes on Chandler Transactional Profit Methods OECD Invitation to Comment on Issues Notes on Transactional Profit Methods Throughout this document, “KPMG” [“we,” “our,” and “us”] refers to KPMG LLP’s Global Transfer Pricing Services group. It does not refer to KPMG International, a Swiss cooperative. KPMG International provides no client services. The OECD has requested comments on a series of Issues notes that was drafted by the Working Party No. 6 of the OECD Committee on Fiscal Affairs (“the Working Party”) on the Transactional Profit Methods. The Issues notes, which were released on January 25, 2008, seek to build on the experience acquired by countries in applying transactional profit methods since the adoption of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (“the TP Guidelines”) in 1995 and on comments received from the business community in response to an earlier open invitation to comment on issues in relation to profit methods that was released in February 2006. This submission provides KPMG’s Global Transfer Pricing Services (KPMG) comments on the Issues notes drafted by the Working Party. The Working Party’s draft on the ...