Transfer Pricing and the Arm's Length Principle After BEPS

by Richard Collier, Joseph L. Andrus

This is the first book to present a sustained analysis and critique of arm's length based transfer pricing rules following the G20 / OECD Base Erosion and Profit Shifting (BEPS) project. The book considers the nature and scope of transfer pricing rules based on the arm's length principle starting with an explanation of how the rules were created and how they evolved over time. It provides how internationally accepted transfer pricing rules were applied immediatelyprior to the BEPS project, and describes the principal problems that had arisen with those rules.The issues highlighted include problems relating to the complexity of the rules, the use and availability of comparables, and, in particular, problems permitting avoidance and income shifting, including problems related to low tax entities with 'excessive capital'. Having described the pre-BEPS rules and inherent problems, the book goes on to examine the extent to which the work undertaken by the BEPs project provides a solid foundation for future transfer pricing determinations and theproblems that remain after BEPS. It identifies those issues on which the BEPS output has been positive, and also those issues which BEPS has not successfully addressed and which remain problematic.This book is the most detailed and up-to-date publication on this highly topical and often controversial topic.

324 pages, Kindle Edition

Published December 8, 2017

About the author

Richard Collier, was born in London, England in 1924. He joined the Royal Air Force at eighteen after that, as a war correspondent, he traveled throughout the Far East.

He worked on numerous British and American magazines and wrote more than half a dozen books about the Second World War.

Reviews

[Patrick Coast · Rating 4 out of 5]

Great history of international tax system. Good overview of evolution of transfer pricing rules and critical analysis of principles/contradictions. Weaker on policy recommendations at end of book. It’s out of scope, but really shouldn’t have been.