The BEPS Report on Risk Allocation: Not So Functional

Journal
Hafkenscheid, R.P.F.M.
International
International Transfer Pricing Journal 2017 (Volume 24), No. 1
PriceUSD 45

In this article, the revised interpretation of the arm’s length principle on risk allocation as presented in the BEPS Final Report on Action 8-10 is discussed. By analysis of the main points, the author contests this interpretation and suggests an alternative approach.