OECD Transfer Pricing Guidelines (TPG), after 2015 BEPS documents, enforce the rule according to which the intangible funder is not allowed to gain intangibles' revenues when lacking ability to control the project development performed by other group companies.OECD rule has a primary anti-abuse...

Because the actions of multinational corporations have a clear and direct effect on the flow of capital throughout the world, how and why these firms behave the way they do is a major issue for national governments and their policymakers. With an unprecedented ability to adjust the scale,...

On 5th October 2015, the OECD along with G20 finally released a fifteen-point action plan on their project on Base Erosion and Profit Shifting (BEPS). Issues related to transfer pricing formed a major part of this final report, with BEPS Action Plan 8-10 focusing on it exclusively. The actions...

The paperwork aims at comparing interpretation of the definition of intangibles and ownership determination in order to apply transfer pricing laws and rules in the US, Russia, and particularly the OECD transfer pricing approach.Transfer pricing of intangibles is a hot issue among OECD members....

Well before the OECD's BEPS Project began, there has been an ongoing debate over whether the Arm's Length Principle (ALP) provides an adequate basis for determining the allocation of income between associated enterprises in cross-border controlled transactions, and whether the principle should...