Resumen de Contractual Arrangements and the Delineation of a Transaction: A Duo in Crisis Mode
This article highlights the evolving relationship between contractual arrangements and the delineation of a transaction for transfer pricing purposes since the release of the first edition of the transfer pricing guidelines in 1979. It shows that BEPS-related guidance on the matter has created a serious rift between the delineation of a transaction and the relevance of contractual arrangements. This creates uncertainty and ambiguity for Multinational Enterprises (MNEs) and tax authorities.
