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