Results 81 to 90 of about 372 (131)

On the Apparent Widespread Misapplication of the OECD Transfer Pricing Guidelines

Bulletin for International Taxation, 2022
In 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

Retroactive Application of the OECD Transfer Pricing Guidelines for Interpretation in Transfer Pricing Issues

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 Status of the OECD Transfer Pricing Guidelines in the Post-BEPS Dynamic

International Tax Studies, 2020
Despite 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.
exaly   +2 more sources

Guaranteed Unclarity? – A Critical Analysis of Paragraph 10.161 of the OECD Transfer Pricing Guidelines

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

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