Ownership under OECD Rules: Transfer Pricing and Beyond

This article examines OECD rules regarding ownership of assets within an international group. This topic is rapidly developing into a growing source of controversy as taxpayers are confronted with different concepts of ownership in recent OECD documents. The authors call upon the OECD to develop in this area a set of rules that apply for various purposes, including transfer pricing, the allocation of profits to a permanent establishment and relief from withholding tax.