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by Johann H. Müller (Author)
How many of us still have time to read 660+ page guidelines? How many of us have time to take those guidelines and combine them with chapters adopted after the guidelines were published? How does a student begin to study a work of this size, without getting hopelessly lost? This book reflects my love for systematic thinking and reducing clutter. It is aimed at giving fast, accurate, information through diagrams and summaries. I believe it may fill a need at a time where we are buried under information and do not always have time to read ten page articles, hundred-page court decisions, or six hundred page guidelines. This book does not pretend to be a replacement of the 2017 OECD Transfer Pricing Guidelines; it is an introduction, giving an overview of the wide variety of topics covered, with paragraph references to the underling Guideline paragraphs, so that we know where to find them. In this book, the 2017 OECD Transfer Pricing Guidelines are summarized three times: first as a one-page overview, then as a longer executive summary and finally as an extended summary of most of the paragraphs of the 2017 OECD Transfer Pricing Guidelines. The extended summary references the actual paragraphs in the 2017 OECD Transfer Pricing Guidelines. As the 2017 OECD Transfer Pricing Guidelines is a live document, which is continuously updated, I will substitute existing the 2017 OECD Transfer Pricing Guidelines chapters and paragraphs with draft and final material published after 2017. These texts are clearly marked and will first concern the profit allocation to PEs, the profit split method and financial transactions, when those documents are finalised by the OECD.The book follows the order of topics as given in the actual guidelines, albeit that I have added to Annexes to the different chapters in the chapters where they belong. This book is only descriptive: I have not given my opinion about the choices made, though it is difficult to make a summary without some degree of interpretation.
