The Substance Requirement in the OECD Transfer Pricing Guidelines: What Is the Substance of the Substance Requirement?
Journal
Country
International
Published Date
Issue
International Transfer Pricing Journal 2014 (Volume 21), No. 1
Document
The author investigates the content of the substance requirement in the OECD Guidelines. When relevant, it is compared to the substance requirement in the US transfer pricing regulations and other sources of international tax law, such as the OECD Model Tax Convention.