In October 1999, the OECD published an update to the1995 OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (hereafter referred to as the "Guidelines"). This update is in the form of a new Annex to the Guidelines that gives guidance on conducting advance pricing arrangements under the mutual agreement procedure (MAP APAs). The Annex becomes an integral part of the Guidelines as shown by the decision of the OECD council on 28 October to amend its original...