The Resource Observations on OECD discussion draft on business restructuring : is the notion of control over risk at arm's length?

Observations on OECD discussion draft on business restructuring : is the notion of control over risk at arm's length?

Label
Observations on OECD discussion draft on business restructuring : is the notion of control over risk at arm's length?
Title
Observations on OECD discussion draft on business restructuring : is the notion of control over risk at arm's length?
Creator
Subject
Language
eng
Summary
This article provides an analysis of the notion of control over risk as explained in the excess inventory example included in the OECD Discussion Draft on Transfer Pricing Aspects of Business Restructurings. It further discusses why the allocation of risk depicted in that example should not be regarded as at arm's length
Citation source
In: International transfer pricing journal. - Amsterdam. - Vol. 16 (2009),
http://library.link/vocab/creatorName
  • Musselli, A
  • Musselli, A.C
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • OECD
  • reorganization
  • cross-border reorganization
  • notional principal contract
  • arm's length principle
  • transfer pricing
Label
Observations on OECD discussion draft on business restructuring : is the notion of control over risk at arm's length?
Instantiates
Publication
Label
Observations on OECD discussion draft on business restructuring : is the notion of control over risk at arm's length?
Publication

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