Friday, April 01, 2011

Top former U.S. tax official makes devastating attack on OECD transfer pricing system

Michael Durst, a former director of the U.S. Internal Revenue Service's Advance Pricing Agreement Program, wrote an article in Tax Notes in January which constitutes a devastating attack on the OECD's jealously defended system for transfer pricing arrangements, the basis for taxing multinational corporations internationally.

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.

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