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Transfer Pricing and the Arm's Length Principle After BEPS

Richard Collier and Joseph L Andrus

Published in print August 2017 |

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This book examines the transfer pricing rules, including the arm's length principle (ALP), in the context of the G20 / OECD Base Erosion and Profit Shifting (BEPS) project. It considers the nature and scope of the transfer pricing rule starting with an explanation of how and on what basis the rules were created. It provides clear analysis of the rules as they are applied currently, and tackles problems with the model. The issues highlighted include problems relating to the complexity of the rules the use of comparables and, in particular, the problem of ‘excessive capital’. Having established the rules and inherent problems, the book goes on to examine the extent to which the work undertaken by the BEPs project will provide a solid foundation for future transfer pricing determinations.

Book.  320 pages.  186806 words.  Illustrated.

Subjects: Law

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Table of Contents

Introduction in Transfer Pricing and the Arm's Length Principle After BEPS

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1 The Emergence of the ALP in Transfer Pricing and the Arm's Length Principle After BEPS

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2 The Development of the ALP in Transfer Pricing and the Arm's Length Principle After BEPS

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3 Practical Application of the Arm’s Length Principle in Transfer Pricing and the Arm's Length Principle After BEPS

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5 Capital in Transfer Pricing and the Arm's Length Principle After BEPS

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6 BEPS Modifications to Transfer Pricing Rules in Transfer Pricing and the Arm's Length Principle After BEPS

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7 Evaluation of BEPS Transfer Pricing Measures in Transfer Pricing and the Arm's Length Principle After BEPS

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8 Prospects for the ALP after BEPS in Transfer Pricing and the Arm's Length Principle After BEPS

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