Where Have All the Transfer Pricing Safe Harbors Gone? A Plea for Reinvigoration

Patricia Gimbel Lewis argues for the resurrection of the OECD's work on safe harbors, which was sidelined when the organization took on its ambitious rewrite of the global tax rules under the Action Plan on Base Erosion and Profit Shifting. The need to get "easy" transfer pricing issues off the table has become more acute given the continued focus and challenge of thorny issues such as intangibles, tax havens, and cash boxes, as well as the shortage of government administrative resources. For the complete article, please click on the link above to view a PDF.