A Transfer Pricing Model Based on Safe Harbours to Accommodate the Needs of Low-Capacity Developing Countries

Journal
Almeida, A. de
International
International Transfer Pricing Journal 2023 (Volume 30), No. 4
Price USD 45

This article argues that a safe harbour transfer pricing policy combined with predetermined margins and markups based on economic parameters will fit the scarce resources of low-capacity developing countries and be a workable tool to address base erosion and profit shifting.