Amsterdam Center for Tax Law
Insights into PE Attribution & Transfer Pricing Rules
Problems with the PE Attribution Rules
Problems with the PE threshold
DEMPE v. Contractual agreements in transfer pricing of IP after BEPS
Quantitative Risk Allocation in Transfer Pricing: Economist Perspectives and Critiques
The US and Brazil: Transfer pricing risk allocation different from the OECD guidance
Corporate Social Responsibility and Ethics in Transfer Pricing after BEPS and Pillar One