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| Content Provider | OECD iLibrary |
|---|---|
| Organization | OECD |
| Abstract | Part B of this chapter provides a discussion of other approaches that might be used to approximate arm's length conditions when traditional transaction methods cannot be reliably applied alone or exceptionally cannot be applied at all. The other approaches are referred to in the discussion here as "transactional profit methods," i.e. methods that examine the profits that arise from particular transactions among associated enterprises. The only profit methods that satisfy the arm's length principle are those that are consistent with the profit split method or the transactional net margin method as described in these Guidelines. In particular, so-called "comparable profits methods" or "modified cost plus/resale price methods" are acceptable only to the extent that they are consistent with these Guidelines. Part C discusses an approach that cannot reliably approximate arm's length conditions: global formulary apportionment. OECD member countries reiterate their support for the arm's length principle and so reject the use of global formulary apportionment. |
| Page Count | 22 |
| Starting Page | 67 |
| Ending Page | 88 |
| Language | English |
| Publisher | OECD Publishing |
| Publisher Date | 2009-08-18 |
| Access Restriction | Open |
| Subject Keyword | Finance and Investment Taxation Industry and Services Trade |
| Content Type | Text |
| Resource Type | Chapter |
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