Results 81 to 90 of about 372 (131)
Functional DNA Repair Profiling in Translational Medicine: Benchmarking Comet, γH2AX, and NGS Assays Against Clinical Constraints. [PDF]
Macieja A +4 more
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Climate Action Impacts on Steelmaking Emissions of Persistent Organic Pollutants Highlight a Gap Between the Paris Agreement and the Stockholm Convention. [PDF]
Sun Y +7 more
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A Brief Participatory Workplace Intervention on Dietary Barriers and Healthy Eating Intentions Among Employees: A Pilot Study. [PDF]
Hyży A +4 more
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On the Apparent Widespread Misapplication of the OECD Transfer Pricing Guidelines
Bulletin for International Taxation, 2022In this article, the authors examine the apparent widespread misapplication of the OECD Transfer Pricing Guidelines. Though most evident in relation to the rules on risk introduced by the OECD/G20 Base Erosion and Profit Shifting Project, it is argued that the cause stems from some wider problems with the ALP.
R.S. Collier, I.F. Dykes
exaly +2 more sources
International Transfer Pricing Journal, 2018
The position of soft obligations as legal sources is a continuously discussed topic in international law. As policy documents, guidelines and non-binding agreements often are regularly updated, the question of the applicability of different editions to various points in time may arise.
exaly +2 more sources
The position of soft obligations as legal sources is a continuously discussed topic in international law. As policy documents, guidelines and non-binding agreements often are regularly updated, the question of the applicability of different editions to various points in time may arise.
exaly +2 more sources
The Status of the OECD Transfer Pricing Guidelines in the Post-BEPS Dynamic
International Tax Studies, 2020Despite the vast literature on the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (OECD Guidelines), its status has received little consideration. The image in the literature is that the OECD Guidelines is a significant publication, given the substantial cross-border trade between associated enterprises.
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International Transfer Pricing Journal, 2023
Paragraph 10.161 of the OECD Transfer Pricing Guidelines takes a specific approach to the accurate delineation of financial guarantees by recharacterizing guaranteed debt as a loan to the guarantor followed by an equity contribution to the legal borrower in certain circumstances.
S.Sundar Manivannan, D.van Straten
exaly +2 more sources
Paragraph 10.161 of the OECD Transfer Pricing Guidelines takes a specific approach to the accurate delineation of financial guarantees by recharacterizing guaranteed debt as a loan to the guarantor followed by an equity contribution to the legal borrower in certain circumstances.
S.Sundar Manivannan, D.van Straten
exaly +2 more sources

