How OECD Developments Are Shaping Transfer Pricing
1 October 2010
By Sebastien Gonnet et al.
Transfer pricing as a discipline is being redefined in important ways as a result of initiatives sponsored by the OECD. In this chapter from Recent Trends and Prospects of Transfer Pricing, the authors examine how these developments are shaping transfer pricing. Specifically, the authors examine issues relating to comparability analysis, the use of profit-based methods, the introduction of the significant people functions concept in order to substantiate the attribution of profits to permanent establishments, and business restructurings. The authors conclude that taxpayers and practitioners are entering a more challenging transfer pricing environment, and that it will become harder to support structures that hitherto have been regarded as part of mainstream solutions.
This chapter originally appeared in Recent Trends and Prospects of Transfer Pricing, ed. Arun Kumar, Reseach India Press, 2011, and is republished here with permission from the publisher.
