The comparable profits method and the arm's length principle

In this provocative article the author deals with the question whether the Comparable Profits Method (CPM) is indeed an arm's length transfer pricing method. The author first looks back at the history of the allocation of income to different parts of multinational enterprises, including the predecessors of the current OECD Model Convention. Then, inter alia on the basis of practical use and application of the CPM method, the author presents his conclusion.