7 Evaluation of BEPS Transfer Pricing Measures

Subject(s):

Payment of price — Effects of trade practices — Contract formation and trade practices

This chapter evaluates the changes described in the previous chapter, and considers whether they provide a solid foundation for future transfer pricing determinations. The BEPS transfer pricing outputs are prodigious. They reflect a serious effort to come to grips with issues that have bedeviled transfer pricing practice for many years. In some respects they do so relatively successfully. In other respects, however, improvement has been hard to come by and in some instances the BEPS changes create new concerns, which this chapter considers in more depth. It also looks at some of the collateral consequences that may flow from the BEPS work.