Unlimited Adjustments: Some Reflections on Transfer Pricing, General Anti-Avoidance and Controlled Foreign Company Rules, and the “Saving Clause”

Abstract

In light of Actions 8-10 of the OECD/G20 BEPS Project, this article considers the interaction and increasing pressure points between transfer pricing and general anti-avoidance and controlled foreign company rules, and the effect of article 9 of the OECD Model in light of the saving clause in article 1(3).