OECD/International - On the Apparent Widespread Misapplication of the OECD Transfer Pricing Guidelines

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.

Richard Collier, Ian F. Dykes