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International - Ownership under OECD Rules: Transfer Pricing and Beyond

Country:
International
Author:
M. Kanter; J. Reijnierse; H. Vollebregt
Issue:
European Taxation, 2010 (Volume 50), No 5
Published:
10 March 2010
This article examines OECD rules regarding ownership of assets within an international group. This topic is rapidly developing into a growing source of controversy as taxpayers are confronted with different concepts of ownership in recent OECD documents. The authors call upon the OECD to develop in this area a set of rules that apply for various purposes, including transfer pricing, the allocation of profits to a permanent establishment and relief from withholding tax.
 
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