Pros and Cons of Safe Harbors, and Advice to Tax Authorities
OECD / Safe Harbors / Transfer Pricing

Pros and Cons of Safe Harbors, and Advice to Tax Authorities

Why is it worth weighing pros and cons of safe harbors*? Because the OECD’s June 6, 2012 draft endorses safe harbors and presents three sample memoranda that countries may use to negotiate bilateral safe harbors. Also, most would say that the IRS has been successful with instituting safe harbors on interest rates for intercompany loans, and … Continue reading