This book examines the transfer pricing rules, including the arm's length principle (ALP), in the context of the G20 / OECD Base Erosion and Profit Shifting (BEPS) project. It considers the nature and scope of the transfer pricing rule starting with an explanation of how and on what basis the rules were created. It provides clear analysis of the rules as they are applied currently, and tackles problems with the model. The issues highlighted include problems relating to the complexity of the rules the use of comparables and, in particular, the problem of ‘excessive capital’. Having established the rules and inherent problems, the book goes on to examine the extent to which the work undertaken by the BEPs project will provide a solid foundation for future transfer pricing determinations.