Friday, May 18, 2012

Quote of the day 2: breathless on OECD transfer pricing rules

For transfer pricing enthusiasts - and yes, there is a growing number of them these days - here is another for our quote of the day series. It comes from Michael C. Durst, a former director of the U.S. IRS' advance pricing agreement program.
Let me quote from paragraph 1.9, which the OEeD re-issued only this past July. Paragraph 1.9 starts with the following undocumented assumption: "The arm's length principle has ... been found to work effectively in the vast majority of cases." As someone who has worked hands-on with the arm's length principle for about twenty years, I am left breathless by this assertion. In my experience, the arm's length standard rarely if ever works effectively.
It's from this presentation, which appears to be subscription-only. If you have a subscription, fasten your seat belt before reading. It is devastating. One more for our transfer pricing page.

And the bandwagon rolls on . . .


Post a Comment

<< Home