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By Oliver R. Hoor and Keith O’Donnell, Atoz*
On 1 December 2014, the OECD released a discussion draft (the “Discussion Draft”) on Action 8, 9 and 10 of the Base Erosion and Profit Shifting (“BEPS”) Action Plan which proposes revisions to Chapter I of the OECD Transfer Pricing Guidelines(1) and a number of special measures for public consultation. This article provides a critical overview of the proposals and analyses how these may change the application of the arm’s length principle.
1. Introduction
The arm’s length principle is the international transfer pricing standard that OECD member countries have agreed should be used for tax purposes by MNE groups and tax administrations. The arm’s length principle requires that, for tax...
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