Of all the international tax issues on the agenda today, perhaps the most difficult for both tax administrations and multinational entities (MNEs) is the tension between Organisation for Economic Co-operation and Development (OECD) member countries and the rest of the world with respect to transfer pricing (TP) principles. MNEs find themselves in the middle, producing a material danger of double or multiple taxation.

There are at least six groups with distinct voices in this area of tension...

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