Skip to main content
SpringerLink
Log in

Richard Collier and Joseph Andrus: transfer pricing and the arm’s length principle after BEPS

Oxford University Press, Great Clarendon Street, Oxford, OX2 6DP, United Kingdom, 2017, 306 pages, ISBN 978–0–19–880291–4

  • Book Review
  • Published:
Business Economics Aims and scope Submit manuscript

This is a preview of subscription content, log in via an institution to check access.

Access this article

Log in via an institution

Price excludes VAT (USA)
Tax calculation will be finalised during checkout.

Instant access to the full article PDF.

Institutional subscriptions

Notes

  1. The OECD/G20 BEPS project has been comprehensive and sophisticated. An effort begun in 2012, the OECD BEPS Multilateral Instrument consisting of fifteen actions, which was adopted at the end of 2016, and has since been signed by over 78 jurisdictions. It came into force in July 2018. Under its inclusive framework, over 100 countries are collaborating to implement the BEPS measures. The 15 actions equip governments with the tools to address tax avoidance, ensuring that profits are taxed where economic activities generating the advantages are performed, and value is created.

  2. Formulary apportionment, also known as unitary taxation, is a method of allocating profit earned (or loss incurred) by a corporation or corporate group to a particular tax jurisdiction in which the corporation or group has a taxable presence. It is an alternative to the separate entity accounting approach of the ALP. In contrast, formulary apportionment attributes the corporation's total worldwide profit (or loss) to each jurisdiction, based on factors such as the proportion of sales, assets, or payroll in that jurisdiction.

  3. According to the authors.

  4. Here risk connotes basic economic risk-bearing within the confines of the multinational group. Examples include inventory risk, exchange rate risk, financing risk, including indemnification and guarantee fees, and cost sharing. An entity bearing risk does so in hopes of earning a commensurate reward. More risk-taking by an entity implies a higher return to that entity’s functions.

  5. In total, the BEPS project  received more than 1400 submissions from industry, advisers, NGOs, and academics, totaling approximately 2000 pages of comments. Further, 11 public consultations were held, gathering viewpoints from a variety of stakeholders across the international tax spectrum.

Author information

Authors and Affiliations

  1. College of Business Administration, The University of Texas at Arlington, Box 19479, Business Building Room 309, Arlington, TX, 76019, USA

    William J. Seeger

Authors
  1. William J. Seeger
    View author publications

    You can also search for this author in PubMed Google Scholar

Corresponding author

Correspondence to William J. Seeger.

Additional information

Publisher's Note

Springer Nature remains neutral with regard to jurisdictional claims in published maps and institutional affiliations.

Rights and permissions

Reprints and permissions

About this article

Check for updates. Verify currency and authenticity via CrossMark

Cite this article

Seeger, W.J. Richard Collier and Joseph Andrus: transfer pricing and the arm’s length principle after BEPS. Bus Econ 54, 182–184 (2019). https://doi.org/10.1057/s11369-019-00119-6

Download citation

  • Published:

  • Issue Date:

  • DOI: https://doi.org/10.1057/s11369-019-00119-6

Search

Navigation