International - The Transactional Profit Methods in Practice: A Survey of APA Reports
- J.L. Cooper; R. Agarwal
- International Transfer Pricing Journal, 2011 (Volume 18), No 1
- 25 November 2010
One of the main changes in the 2010 version of the OECD Transfer Pricing Guidelines is the replacement of the formal hierarchy of transfer pricing methods with a “most appropriate method to the circumstances of the case” standard. Against this background, this article considers the extent of use of the transactional profit methods in practice over the last two decades.