by the OECD/G20 Inclusive Framework on BEPS in October 2021, Amount B provides for a simplified and streamlined approach …

following the G20 / OECD Base Erosion and Profit Shifting (BEPS) project. The book considers the nature and scope of transfer … evolved over time. It provides how internationally accepted transfer pricing rules were applied immediately prior to the BEPS … avoidance and income shifting, including problems related to low tax entities with 'excessive capital'. Having described the pre-BEPS …

According to plans put forward by the OECD/G20 Inclusive Framework on BEPS, a share of residual profit earned by …