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International - The “Most Appropriate Method” as the New OECD Transfer Pricing Standard: Has the Hierarchy of Methods Been Completely Eliminated?

J. Ahmadov
International Transfer Pricing Journal, 2011 (Volume 18), No 3
16 May 2011
Ever since the OECD Discussion Draft with proposed amendments to Chaps. I-III of the OECD Guidelines came out, it has stirred opinions on the application of the new proposed standard for the hierarchy of transfer pricing methods. This article will seek to provide some answers to questions related to this topic by analysing the history of the hierarchy of transfer pricing methods and its further development, and will consider some of the public comments issued in response to the Discussion Draft. A general snapshot of the history of the US transfer pricing rules and a comparative analysis with the US best-method rule will be also included.
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