On the Apparent Widespread Misapplication of the OECD Transfer Pricing Guidelines

Journal
International; OECD
Bulletin for International Taxation 2022 (Volume 76), No. 1
In this article, the authors examine the apparent widespread misapplication of the OECD Transfer Pricing Guidelines. Though most evident in relation to the rules on risk introduced by the OECD/G20 Base Erosion and Profit Shifting Project, it is argued that the cause stems from some wider problems with the ALP.