International - Recognition of the Actual Transactions Undertaken
- Giedre Liaugminaite
- International Transfer Pricing Journal, 2010 (Volume 17), No 2
- 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.