International - (Non-)Recognition of Transactions between Associated Enterprises: On Behaving in a Commercially Rational Manner, Decision-Making Traps and BEPS
- M.A. de Lange; P. Lankhorst; R. Hafkenscheid
- International Transfer Pricing Journal, 2015 (Volume 22), No 2
- 6 February 2015
The possibilities for reclassifying and disregarding controlled transactions between associated enterprises are explored in this article by means of analysing OECD guidance in this area and looking at how such guidance is interpreted and implemented by tax authorities, drawing on the Netherlands as a specific example. The relevance of the BEPS project together with various economic theories will also be examined, as well as how such theories interact with OECD guidance on this topic.