Corpus ID: 54639380

Between Formulary Apportionment and the OECD Guidelines: A Proposal for Reconciliation

@inproceedings{AviYonah2009BetweenFA,
  title={Between Formulary Apportionment and the OECD Guidelines: A Proposal for Reconciliation},
  author={R. Avi-Yonah},
  year={2009}
}
While there have been few decided cases under the 1995 Transfer Pricing regulations and the OECD Guidelines, it is clear by now that the transfer pricing problem is as bad as it ever was. That is why my co-authors Kimberly Clausing and Michael Durst and I have recently re-proposed adopting Formulary Apportionment (FA). However, it is clear from the reactions we received that it is unlikely we will persuade advocates of the ALS and in particular the OECD that FA is the way forward (although this… Expand
29 Citations

Figures from this paper

References

SHOWING 1-5 OF 5 REFERENCES
The Rise and Fall of Arm's Length: A Study in the Evolution of U.S. International Taxation
  • 34
“ Memorandum to Congress : You Wouldn ’ t Like Worldwide Formulary Apportionment . ”
  • Tax Notes
  • 1994
“ The Unitary Method and the Myth of Arm ’ s Length . ”
  • Tax Notes
  • 1986