The Virus in the ALP

Richard S Collier · I.F. Dykes

21 citations0/0 files storedBulletin for international taxation

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Corporate Taxation and Avoidance Taxation and Legal Issues COVID-19 Pandemic Impacts

Abstract

In this article, the authors consider various policy, technical and practical implications of the transfer pricing guidance on risk and capital in the light of the COVID-19 pandemic, with special reference to the OECD Transfer Pricing Guidelines and the arm’s length principle.

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2019Five Core Problems in the Attribution of Profits to Permanent Establishments

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2022The OECD/G20 Global Minimum Tax and Dispute Resolution: A Workable Solution Based on Article 25(3) of the OECD Model, the Principle of Reciprocity and the GloBE Model Rules

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