Paying for the Stock

Employee Stock Options: Definitions and Key Concepts

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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 and capital.

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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. 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 and capital.

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