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By Oliver R. Hoor, Atoz *
On 11 July 2017, the OECD released the 2017 Revision of its Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (the “OECD Guidelines”). Several chapters of the OECD Guidelines have been significantly amended as a result of the OECD’s work on the Base Erosion and Profit Shifting (“BEPS”) Project. This article provides a clear and concise overview of the most important changes of the OECD Guidelines.
I. Introduction
The OECD Transfer Pricing Guidelines reflect the consensus of OECD member countries towards the application of the arm’s length principle as provided in Article 9 (1) of the OECD Model Tax Convention. The arm’s length principle is the international transfer pricing...
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