Oecd transfer pricing guidelines

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The Substance Requirement in the OECD Transfer Pricing Guidelines: What Is the Substance of the Substance Requirement?

, 2014
The author investigates the content of the substance requirement in the OECD Guidelines. When relevant, it is compared to the substance requirement in the US transfer pricing regulations and other sources of international tax law, such as the OECD Model ...
Monsenego, Jérôme,
exaly +1 more source

Soft Law, Hard Realities and Pragmatic Suggestions: Critiquing the OECD Transfer Pricing Guidelines

, 2012
This paper briefly reviews and critiques the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (2010). It comments on the political, economic and legal contexts in which transfer pricing issues arise and the “soft law”
Jinyan Li, Li, Jinyan
exaly +2 more sources

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arm's length principle

Revised OECD Transfer pricing Guidelines and the Czech tax policy

Acta Universitatis Agriculturae Et Silviculturae Mendelianae Brunensis, 2014
Veronika Solilova
exaly

On the Apparent Widespread Misapplication of the OECD Transfer Pricing Guidelines

2022
exaly

Annex to the OECD Transfer Pricing Guidelines

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022
exaly

The Use of Paragraphs 1.119 to 1.128 of the 2017 OECD Transfer Pricing Guidelines for the Application of Transfer Pricing Rules

Intertax, 2020
exaly

OECD Transfer Pricing Guidelines as a Quasi Source of Law in a Post-BEPS World – Legislative and Judicial Developments from a Polish Perspective