2011 review: transfer pricing

How many readers would have predicted a year ago that as 2011 draws to a close the Euro would be on the brink of collapse and many western economies would be facing another recession? Similarly while well informed readers might have been aware of the forthcoming OECD project on intangibles how many realised the potential of the CCCTB to eliminate transfer pricing in Europe or that the role of the OECD in transfer pricing might be called into question?

Goodbye transfer pricing hello CCCTB?

Make transfer pricing redundant. Do away with the arm’s-length principle. Such concepts might have seemed inconceivable a year ago to many readers but those would be the consequences in Europe at least ...