The IRS's position should not be considered to conflict with the arm's length principle. The OECD countries can always hold this view against the U.S., by stating that highly valuable marketing intangibles were created in the hands of OECD distributors. Now that it has been determined that U.S....

This paper aims at providing a comprehensive overview of existing literature on the topic of comparability adjustments. Based on existing literature the most commonly used adjustments can be categorized in two broad categories: “accounting and financial risks adjustments” and...