Introduction to the Survey of the Profit Split Method across Jurisdictions

This report examines the OECD guidance on the transactional profit split method (PSM) as set out in the OECD Transfer Pricing Guidelines and analyses how the PSM is implemented and applied in the domestic legislation and practice of selected jurisdictions.This article forms part of a special issue of the International Transfer Pricing Journal and introduces the other contributions in that issue, which examine Belgium, France, Germany, Ireland, Italy, Korea, the Netherlands, Portugal,Spain and the United States.