The Resource Controlling risks from a transfer pricing perspective

Controlling risks from a transfer pricing perspective

Label
Controlling risks from a transfer pricing perspective
Title
Controlling risks from a transfer pricing perspective
Creator
Subject
Language
eng
Summary
This article examines risk in relation to the OECD's Discussion draft on the transfer pricing aspects of business restructurings. First it comments on the meaning of the word "control" in the context of paragraph 1.27 of the OECD Guidelines as requested at the end of Chapter B.1 of issue Note no. 1 by applying the information on "control" in the context obtained from management literature, and subsequently on what functions or decisions typically amount to such control; and, second, on whether it is 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 the former as service provider in the absence of an independent source of information (as also requested at the end of Chapter B.1 of issue Note no. 1)
Citation source
In: Tax planning international transfer pricing. - London. - Vol. 10 (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
  • risk
  • control
Label
Controlling risks from a transfer pricing perspective
Instantiates
Publication
Label
Controlling risks from a transfer pricing perspective
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
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