OECD - Observations on OECD Discussion Draft on Business Restructuring: Is the Notion of Control over Risk at Arm’s Length?
- A. (Andrea) Musselli; A. (Alberto) Musselli
- International Transfer Pricing Journal, 2009 (Volume 16), No 4
- 1 July 2009
This article provides an analysis of the notion of control over risk as explained in the excess inventory example included in the OECD Discussion Draft on Transfer Pricing Aspects of Business Restructurings. It further discusses why the allocation of risk depicted in that example should not be regarded as at arm’s length.