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Please upgrade your browser to improve your experience. Over recent years, stock-options have come to account for an increasing share of executive pay packages.

This has given rise to lively debate regarding their effect on incentives, risk taking and corporate governance. Comments on national taxation issues will be contained in a study on domestic tax issues to be released, along with the first two studies, in an OECD publication later this year.

As a first step, following discussions in its Committee on Fiscal Affairs, the OECD is making changes to the Commentary on its Model Tax Convention, the basic document for the negotiation, application and interpretation of the global network of bilateral tax treaties that govern taxation of cross-border income oecd employee stock options capital.

The Commentary is not binding, but it gives guidance to oecd employee stock options on forex primeros pasos to interpret and implement the provisions of the Model Tax Convention.

Because of the complexity of the issues and the range of different circumstances to which they can apply, the OECD does not prescribe any single specific response. It does, however, stress the importance of intra-group documentation to support the intent of the parties at the time that a stock-option plan is set up: Organisation for Economic Co-operation and Development OECD.

The granting of stock-options to employees of an associated enterprise resident in another tax jurisdiction: The impact of provision of a stock-options plan on other intra-group transactions where the transfer pricing method to be applied to these other transactions is sensitive to employee remuneration, and the impact of stock-options on comparability where employee remuneration of either the taxpayer or third party comparables is materially impacted by stock-options.

The impact of employee stock-options on Cost Contribution Arrangements within a multinational enterprise: Related Documents Cross-border income tax issues arising from employee stock option plans Employee Stock Option Plans: Impact on Transfer Pricing. Terms and Conditions Privacy Policy. Follow us Social Media: Facebook Twitter YouTube LinkedIn Flickr RSS Oecd Direct.