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International - Rise of a New Standard: Profit Location in Countries of Important Intangible Functions Managers

Country:
International,OECD
Author:
A. (Andrea) Musselli; A. (Alberto) Musselli
Issue:
International Transfer Pricing Journal, 2017 (Volume 24), No 5
Published:
17 August 2017
This article looks into the arm’s length principle as it has been re-formulated in the new chapter VI of the OECD Guidelines, along the lines of the OECD Final Report on Actions 8-10 and related documentation on BEPS. The authors summarize the major changes of the revised (and materially different) arm’s length principle, analyse the particulars of Example 17 included in the new chapter VI of the OECD Guidelines and discuss the effect of the changes on enforcing the rules on return claims on profits from intangibles.
 
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