Introductory speech - Income allocation in the 21st century : the end of transfer pricing?

Journal
Hamaekers, H.M.A.L.
International Transfer Pricing Journal 2005 (Volume 12), No. 3
FormatPDF
EUR
40
| USD
45
(VAT excl.)

In his introductory speech, professor Hamaekers first describes the two main different systems of allocating income to entities belonging to an multinational enterprise, and then discusses the development of the OECD output on transfer pricing, followed by an analysis of what went wrong with the arm's length principle. Finally the question was broached whether formulary apportionment is a realistic alternative for the arm's length principle.