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- Preliminary Material
- Main Text
- Introduction
- 1 The Emergence of the ALP
- Preliminary Material
- A Introduction
- B Developing the Founding Principles of International Taxation
- C Early Work of the ICC on Income Allocation
- D Revised ICC Proposals of 1924 on Double Taxation
- E The First Involvement of the League of Nations
- F Early Work of the League of Nations Fiscal Committee 1929–33
- G Detailed Work on the Allocation of Profits, 1930–3
- H The 1933 Draft Model Convention on the Allocation of Profits
- I The London and Mexico Model Tax Treaties
- J The ALP Emergent
- 2 The Development of the ALP
- Preliminary Material
- A Introduction
- B Establishing the Primacy of the ALP
- C Elaborating the ALP
- D Confronting the Problems of the ALP
- E Proliferation of Transfer Pricing Regimes
- F The ALP Immediately Prior to BEPS
- 3 Practical Application of the Arm’s Length Principle
- Preliminary Material
- 3.01
- 3.02
- 3.03
- 3.04
- 3.05
- A Applying the Arm’s Length Principle
- B Transactional Approach
- C Comparability
- D Functional Analysis
- E Transfer Pricing Methods
- F Intangibles and Cost Contribution Arrangements
- G Services
- H Transfer Pricing Documentation
- I Attributing Profits to Permanent Establishments
- J Dispute Resolution
- 4 Practical and Theoretical Problems Encountered in Applying the Arm’s Length Principle
- Preliminary Material
- 4.01
- 4.02
- 4.03
- 4.04
- 4.05
- A Conceptual Problems Encountered in Applying Transfer Pricing Rules Based on the Arm’s Length Principle
- B Important Practical Difficulties Encountered in Applying ALP-Based Transfer Pricing Rules
- C Purpose and Scope of ALP-Based Transfer Pricing Rules
- 4.77
- 1 Treaty Interpretation Issues: The Purpose and Scope of ALP-Based Transfer Pricing Rules
- 2 Issues Related to the Scope of Article 9
- 5 Capital
- Preliminary Material
- A Introduction
- B The Nature of the Capital Issues under Consideration
- C Transfer Pricing Treatment of Capital Issues Prior to BEPS
- D Relevance of the ALP to Capital Transfers
- E Treatment of Capital under Article 7
- F Capital Issues in the Run-up to BEPS
- 6 BEPS Modifications to Transfer Pricing Rules
- Preliminary Material
- 6.01
- A The BEPS Action Plan
- B The Real Deal—Delineating and Disregarding Transactions
- C Risk
- D Excessive Capital/Returns to Capital
- E Intangibles
- F Profit Splits, Global Value Chains, and Financial Transactions
- G Transparency, Documentation, and Country-by-Country Reporting
- H Other BEPS Work with Transfer Pricing Consequences
- I Transfer Pricing Problems Not Addressed in the BEPS Reports
- 7 Evaluation of BEPS Transfer Pricing Measures
- Preliminary Material
- 7.01
- 7.02
- A Alignment of Income and Value Creation
- 7.03
- 7.04
- 7.05
- 7.06
- 7.07
- 7.08
- 1 Risk and Control of Risk
- 2 Undercapitalization, Overcapitalization, and the Rewards to Funding Entities
- 3 Recognition, Delineation, and Disregard of Taxpayer Transactions
- 4 Ownership of Intangibles, Cost Contribution Agreements, and the Required Reward for Important Intangible-Related Functions
- B Complexity: The Cost of the Cure
- C Addressing the Lack of Reliable Comparables
- D Permanent Establishments, Interest Expense, and Transfer Pricing
- E Administrative Matters
- F Unaddressed Issues
- 8 Prospects for the ALP after BEPS
- Preliminary Material
- A Assessment of the ALP after BEPS
- B General Options for the Future
- C Potential Simplifying Enhancements of the Existing ALP Framework
- D More Fundamental Changes to the Operation of the ALP
- E Non-ALP Alternatives
- F The Future
- Further Material
- [35.175.191.46]
- 35.175.191.46
