Abstract

This article outlines the changes introduced by BEPS Actions 8–10 on the transfer pricing comparability analysis, focusing in particular on the new comparability factors and the new role of the ‘control over risk’ criterion, and discusses its application on the attribution of profits to permanent establishments

Full Text
Paper version not known

Talk to us

Join us for a 30 min session where you can share your feedback and ask us any queries you have

Schedule a call