A Fresh View on the Outcome-Testing Approach versus Price-Setting Approach: Discussion and Recommendations Regarding the Timing of Benchmarking Studies

The authors discuss the practical implications of the outcome-testing approach and the price-setting approach, and, based on an example, offer some suggestions and recommendations regarding the wording of paragraphs 3.67 to 3.71 of the OECD Guidelines (2010) for setting and testing transfer prices in practice, with the aim of minimizing the risk of double taxation.