Safe at Last? Transfer Pricing Safe Harbors on the Horizon
09.06.2012
Bloomberg BNA
Article
Excerpt taken from the article.
[Patricia Gimbel Lewis] builds on a 2011 article advocating wider use of safe harbors, exploring past
resistance to those mechanisms and analyzing the Organization for Economic Cooperation
and Development's June 6 draft, which not only endorses the simplification measures but
sets forth three sample memoranda that countries may use to negotiate bilateral safe harbors
for specific services.
Click on the above pdf to read the full article.
This article was published in Bloomberg BNA's Tax Management Transfer Pricing Report, Vol. 21 No. 9, 9/6/2012. Copyright © 2012 by The Bureau of National Affairs, Inc.
[Patricia Gimbel Lewis] builds on a 2011 article advocating wider use of safe harbors, exploring past
resistance to those mechanisms and analyzing the Organization for Economic Cooperation
and Development's June 6 draft, which not only endorses the simplification measures but
sets forth three sample memoranda that countries may use to negotiate bilateral safe harbors
for specific services.
Click on the above pdf to read the full article.
This article was published in Bloomberg BNA's Tax Management Transfer Pricing Report, Vol. 21 No. 9, 9/6/2012. Copyright © 2012 by The Bureau of National Affairs, Inc.
