The Resource A note on controlling risks from a transfer pricing perspective

A note on controlling risks from a transfer pricing perspective

Label
A note on controlling risks from a transfer pricing perspective
Title
A note on controlling risks from a transfer pricing perspective
Creator
Subject
Language
eng
Summary
In its Discussion Draft on the transfer pricing aspects of business restructurings, the OECD appears to introduce an additional factor to consider in examining whether the contractual risk allocation is in accordance with the economic substance of the transaction: control over risk. This article comments on the meaning of the word "control" in the context of Par. 1.27 of the OECD Guidelines, and discusses whether is it possible at arm's length to ask the transferor of a risk to perform the day-to-day monitoring and administration functions on behalf of the transferee in cases where it is difficult for the latter to assess the performance of an independent source of information
Citation source
In: Tax management transfer pricing report. - Arlington. - Vol. 18 (2009),
http://library.link/vocab/creatorName
  • Jie-A-Joen, C
  • Lierens, D
  • Moerer, O
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • transfer pricing
  • reorganization
  • risk assessment
Label
A note on controlling risks from a transfer pricing perspective
Instantiates
Publication
Label
A note on controlling risks from a transfer pricing perspective
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
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