TY - JOUR
AB -  OECD 3 INTRODUCTION 123. This discusses the application of the arm's length principle and TP Guidelines to post-restructuring arrangements, based on the existing guidance on the selection and application of transfer pricing methods that is found in the TP Guidelines (in particular Chapters I-III). It also takes account of the current review by the OECD of comparability and profit methods. At this stage, the review of comparability and profit methods is still ongoing and the conclusions that were arrived at and are reproduced below are only tentative and will need to be updated in due course.26 124. The intention is not to develop criteria for selecting and applying a transfer pricing method in postrestructuring cases that would be different from the criteria used in other transfer pricing cases. The arm's length principle and the TP Guidelines do not and should not apply differently to post-restructuring transactions as opposed to transactions that were structured as such from the beginning (see Section B below). The general guidance on the selection of transfer pricing methods applies to business restructuring cases (see Section A below for a description of this general guidance). Business restructurings however raise particular issues and deserve specific consideration 
TI - Issues Note No. 3: Remuneration of Post–Restructuring Controlled Transactions
JF - Intertax
DA - 2009-02-01
UR - https://www.deepdyve.com/lp/kluwer-law-international/issues-note-no-3-remuneration-of-post-restructuring-controlled-Q0O0HFRNBR
SP - 124
EP - 137
VL - 37
IS - 2
DP - DeepDyve
ER -