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International - Recognition of the Actual Transactions Undertaken

Country:
International
Author:
Giedre Liaugminaite
Issue:
International Transfer Pricing Journal, 2010 (Volume 17), No 2
Published:
26 February 2010
This article deals with non-recognition of transactions under Paras. 1.36-1.41 of the OECD Guidelines in light of the guidance provided in the OECD Discussion Draft on the Transfer Pricing Aspects of Business Restructurings. It analyses the interaction among domestic anti-abuse and tax treaty provisions as interpreted by the OECD Guidelines and the OECD Discussion Draft, and examines the practical problems which might result from implementation of OECD Discussion Draft.
 
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