Transfer pricing comparability : perspectives of OECD, Australia and United States

Applying the arm's length principle is becoming harder now that uncontrolled and independent transactions that can serve as comparables are getting rarer. This article looks into recent OECD developments regarding the role of comparability, along with the position of Australia. It concludes with a discussion on new service regulations issued in the United States that could bring some certainty to transfer pricing in relation with services.