Last Updated: 1 December 2016

[IT 12,250] Relevance of OECD material to interpretation of Regulations6 

6
(1) Subject to subregulation (2), these Regulations are to be applied in a manner consistent with—
  • (a)the arm's length principle in Article 9 of the OECD Model Tax Convention on Income and Capital; and
  • (b)the OECD Transfer Pricing Guidelines for Multi-national Enterprises and Tax Administrations approved by the Council of the OECD for publication on 13 July, 1995 (C(95)126/FINAL), as supplemented and updated from time to time.
(2) If there is any inconsistency between the Act, including these Regulations, and the OECD documents referred to in subregulation (1), the Act prevails.