Top former U.S. tax official makes devastating attack on OECD transfer pricing system
He argues, correctly, that the OECD's approach is "based on a fundamental misunderstanding of practical economics" and has other flaws.
The article is subscription-only, so we can't reproduce it here. However, we have produced a TJN summary of the article, which is here.
A must-read for anyone interested in this particular subject. Which is a big and important one.