Is there a divergence between the OECD Transfer Pricing Guidelines and post-BEPS interpretation of the Arm?s Length Principle in OECD materials, with emphasis on the control of risk and value creation?

This minor-dissertation contends that the arm's length principle is not being interpreted and applied in transfer pricing practice as intended by the OECD in its 2022 Transfer Pricing Guidelines (the TPG).1 Whether deliberate or unintentional, such a divergence has the potential to become permanent...

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