Transfer Pricing and the Arm's Length Principle After BEPS

Richard Collier is an Associate Fellow at the Centre for Business Taxation in Oxford and is heavily involved in tax policy work. Previously he was a senior tax partner at PwC, specializing in financial sector tax and transfer pricing and permanent establishment issues. Richard is also a qualified barrister and chartered accountant and holds a Ph.D. in law. Joseph L Andrus was the Head of the Transfer Pricing Unit at the OECD until his retirement in 2014. He was responsible for directing all of the OECD work in transfer pricing including the transfer pricing portions of the OECD project on corporate Base Erosion and Profit Shifting. He is also a member of the United Nations Subcommittee on Transfer Pricing. Prior to joining the OECD, Joseph had 35 years of experience as an advisor on transfer pricing matters. He was a transfer pricing partner at PwC and at Baker & McKenzie, and served in the mid-1980s as Deputy International Tax Counsel at the US Treasury Department He is an attorney and holds a J.D. degree from the University of Chicago Law School.

• Introduction1: The Emergence of the ALP2: The Development of the ALP3: Practical Application of the Arm's Length Principle4: Practical and Theoretical Problems Encountered in Applying the Arm's Length Principle5: Capital6: BEPS Modifications to Transfer Pricing Rules7: Evaluation of BEPS Transfer Pricing Measures8: Prospects for the ALP After BEPS

this book is one of the best pieces on the comprehensive analysis of transfer pricing ever published. ... it is important to highlight that every relevant matter in the field of transfer pricing is commented by the authors not from a mere descriptive standpoint, but always adopting a critical eye that will satisfy even the most rigorous and demanding experts on these matters. For all the aforementioned reasons, the book 'Transfer Pricing and the Arms length Principle after BEPS', by Joseph Andrus and Richard Collier is certainly a must have both in the transfer pricing field, and more generally, in the field of international taxation.