International - The Substance Requirement in the OECD Transfer Pricing Guidelines: What Is the Substance of the Substance Requirement?
- J. (Jérôme) Monsenego
- International Transfer Pricing Journal, 2014 (Volume 21), No 1
- 15 January 2014
The author investigates the content of the substance requirement in the OECD Guidelines. When relevant, it is compared to the substance requirement in the US transfer pricing regulations and other sources of international tax law, such as the OECD Model Tax Convention.