International - The Concept of “Options Realistically Available” under the OECD Transfer Pricing Guidelines
- S. Parekh
- International Transfer Pricing Journal, 2015 (Volume 22), No 5
- 3 September 2015
The author evaluates the transfer pricing concept of “options realistically available”. The article seeks to understand and analyse the meaning of this concept, identifies various factors that must be analysed to determine the options realistically available and briefly discusses some of the financial management tools and economic theories that can be used to apply this concept in practice.