The use of paragraphs 1.119 to 1.128 of the 2017 OECD Transfer Pricing Guidelines for the application of transfer pricing rules Luis Durán Rojo & Paul Nina Nina
By: Durán Rojo, Luis
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Contributor(s): Nina Nina, Paul.
Material type: 
ArticlePublisher: 2020Subject(s): PRECIOS DE TRANSFERENCIA | FISCALIDAD INTERNACIONAL | APLICACION | PRINCIPIO DE PLENA COMPETENCIA | ORGANIZACION DE COOPERACION Y DESARROLLO ECONOMICO
In:
Intertax v. 48, Issues 6-7, June / July 2020, p. 616-623Summary: This article analyses the paragraphs 1.119 to 1.128 of the 2017 OECD Transfer Pricing Guidelines and their relation to the comparability analysis, sham transactions and domestic anti-avoidance rules. The authors discuss the nature of the transfer pricing rules, the limits of the OECD Transfer Pricing Guidelines to the application of transfer pricing rules and the main features of the comparability analysis, sham transactions and the anti-avoidance rules. It is concluded that part of these paragraphs contains recommendations that exceed the purpose of the transfer pricing rules when they are structured over the arm's length principle.
| Item type | Current location | Home library | Call number | Status | Date due | Barcode |
|---|---|---|---|---|---|---|
| Artículos | IEF | IEF | OP 2141/2020/6/7-6 (Browse shelf) | Available | OP 2141/2020/6/7-6 |
Resumen.
This article analyses the paragraphs 1.119 to 1.128 of the 2017 OECD Transfer Pricing Guidelines and their relation to the comparability analysis, sham transactions and domestic anti-avoidance rules. The authors discuss the nature of the transfer pricing rules, the limits of the OECD Transfer Pricing Guidelines to the application of transfer pricing rules and the main features of the comparability analysis, sham transactions and the anti-avoidance rules. It is concluded that part of these paragraphs contains recommendations that exceed the purpose of the transfer pricing rules when they are structured over the arm's length principle.
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