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It's very hard to avoid artificial self dealing between related entities. The OECD transfer pricing arm's length principle [0] is supposed to somewhat solve tha
by markvdb 5y ago
It's very hard to avoid artificial self dealing between related entities. The OECD transfer pricing arm's length principle [0] is supposed to somewhat solve that.
The problem regarding transfer pricing is that the US, the Netherlands, Ireland, Luxemburg, plus most of the places generally reputed to be tax havens have holes in their law you can fly an Antonov AN-225 [1] through.
[0] https://www.oecd-ilibrary.org/taxation/oecd-transfer-pricing-guidelines-for-multinational-enterprises-and-tax-administrations-2010/the-arm-s-length-principle_tpg-2010-4-en https://www.oecd-ilibrary.org/taxation/oecd-transfer-pricing...
[1] https://en.wikipedia.org/wiki/Antonov_An-225_Mriya https://en.wikipedia.org/wiki/Antonov_An-225_Mriya