Contractual Arrangements and the Delineation of a Transaction: A Duo in Crisis Mode

By Robert Robillard - 18 December 2017

Read our latest piece published in Intertax 45/12 titled “Contractual Arrangements and the Delineation of a Transaction: A Duo in Crisis Mode”.

Summary – “This article highlights the evolving relationship between contractual arrangements and the delineation of a transaction for transfer pricing purposes since the release of the first edition of the transfer pricing guidelines in 1979. It shows that BEPS-related guidance on the matter has created a serious rift between the delineation of a transaction and the relevance of contractual arrangements. This creates uncertainty and ambiguity for Multinational Enterprises (MNEs) and tax authorities.”

This article is reproduced with permission from the editor.

Robert Robillard, Ph.D., CPA, CGA, Adm.A., MBA, M.Sc. Econ., M.A.P.
Senior Partner, RBRT Fiscalité / Tax (RBRT inc.)
514-742-8086
robertrobillard@rbrt.ca
rbrt.ca

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