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International - The BEPS Report on Risk Allocation: Not So Functional

Country:
International
Author:
R. Hafkenscheid
Issue:
International Transfer Pricing Journal, 2017 (Volume 24), No 1
Published:
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.
 
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