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6 BEPS Modifications to Transfer Pricing Rules

Richard S Collier, Joseph L Andrus

From: Transfer Pricing and the Arm's Length Principle After BEPS

Richard Collier, Joseph L Andrus

From: Oxford Legal Research Library (http://olrl.ouplaw.com). (c) Oxford University Press, 2023. All Rights Reserved.date: 22 February 2024

Breach of contract — Performance of contract — Payment of price

This chapter describes the principal changes in the application of the ALP adopted in connection with BEPS. From the outset of the BEPS Project in 2013, it was understood that corporate tax base erosion was a multifaceted problem. The ALP had been a direct target of some of the most vocal critics of corporate tax avoidance. It was therefore politically imperative that transfer pricing be one of the primary areas of focus in the BEPS Project. The problems with the transfer pricing system described in the two previous chapters were not secrets by any means. It was well understood that the existing transfer pricing rules, at least in the way they were being applied, were not preventing the type of income shifting into tax favorable locations that the BEPS Project intended to counteract.

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