2020
DOI: 10.54648/taxi2020056
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The Use of Paragraphs 1.119 to 1.128 of the 2017 OECD Transfer Pricing Guidelines for the Application of Transfer Pricing Rules

Abstract: This article aims to analyse the paragraphs 1.119 to 1.128 of the 2017 OECD Transfer Pricing Guidelines and their relation to the comparability analysis, sham transactions and domestic anti-avoidance rules. For this purpose, the authors discuss the nature of the transfer pricing rules, the limits of the OECD transfer pricing guidelines to the application of transfer pricing rules and the main features of the comparability analysis, sham transactions and the anti-avoidance rules. It is concluded that part of th… Show more

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“…Transfer pricing facilitates internal performance measurement and evaluation. By attributing revenues and costs accurately, TNCs can assess the performance of individual entities, products, or business segments, aiding decision-making and resource allocation (Durán R, 2020).…”
Section: Internal Performance Measurementmentioning
confidence: 99%
“…Transfer pricing facilitates internal performance measurement and evaluation. By attributing revenues and costs accurately, TNCs can assess the performance of individual entities, products, or business segments, aiding decision-making and resource allocation (Durán R, 2020).…”
Section: Internal Performance Measurementmentioning
confidence: 99%