721.8 kB - Poledna | Boss | Kurer

suggests that the following items may be relevant inthe negotiation of MOUs:Description of an criteria to be fulfilled by thequalifying enterprises;Description of the qualifying transactions covered;Determination of the arm's length range of testedparty compensation;The years to which the MOU applies;Statement that the MOU is binding on both taxadministrations involved;Reporting and monitoring procedures for the MOU;Documentation and information to be maintainedby the participating enterprises; andA mechanism for resolving disputes.The OECD developed guidance does not provideor specify target returns or metrics for quantitativeratios, which, along with the MOUs, would needto be agreed upon between the countries' competentauthorities for low risk manufacturing services,low risk distribution services, and low risk contractresearch and development services.E NDNOTES123456See Paragraph 3 of the Handbook.The OECD Forum on Tax Administration publisheda report entitled "Dealing Effectively with the Challengesof Transfer Pricing" in January 2012.See Paragraph 56.See Paragraph 73.See paragraph 88.The OECD provides an example definition for qualifyingenterprises and qualifying transactions in thesample MOUs found in Annex I to Chapter IV.33