International - The BEPS Report on Risk Allocation: Not So Functional
- R. Hafkenscheid
- International Transfer Pricing Journal, 2017 (Volume 24), No 1
- 12 January 2017
In this article, the revised interpretation of the arm’s length principle on risk allocation as presented in the BEPS Final Report on Action 8-10 is discussed. By analysis of the main points, the author contests this interpretation and suggests an alternative approach.