About corporate centres, inequality of arms, decrease in controversy and transparency of governments

This article deals with the position of head offices within multinational enterprises, as far as relevant for transfer pricing purposes, in regard of the business models as they exist in practice. The business models discussed are the service fee model and the entrepreneurial model. The author discusses inter alia whether OECD has a preference for either model, and whether there could be a third model which could reduce the current controversy.