Richard Collier and Joseph Andrus: transfer pricing and the arm’s length principle after BEPS
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In 2013, the Organization for Economic Cooperation and Development (OECD) and the Group of 20 (G20) governments embarked on the most significant revision of the international tax rules in a century. The Base Erosion and Profit Shifting initiative (BEPS), launched during the 2007 Financial Crisis, had one goal: revise international tax rules to align them with the major commercial developments in the global economy. This revision explicitly considered the continuing viability of the Arm’s Length Principle (ALP) as the worldwide tax standard in the allocation of income among members of a controlled multinational group.
With the recent conclusion of the BEPS project, now is the ideal time to step back and reflect on the accomplishments and limitations of the BEPS program, as well as the work remaining to address ongoing challenges. In this regard, the authors have done a splendid job; they are uniquely qualified to assess the accomplishments and limitations of this historic...