Abstract:The author discusses specific concerns about the efficacy of the application of transfer pricing rules to aspects of business models that have been addressed in the revisions to the Organisation for Economic Co-operation and Development (OECD) Transfer Pricing Guidelines contained in the 2015 base erosion and profit shifting (BEPS) Report, Aligning Transfer Pricing with Value Creation. Distinctions are made between business models and transfer pricing business models that risk constraining the business to conv… Show more
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