The intention here is to assess the (highly practical) matter of whether the OECD’s Base Erosion and Profit Shifting (BEPS) project has helped, or alternatively hindered, the task for developing countries of applying transfer pricing rules pursuant to the arm’s length principle (ALP).1 Such an assessment is not concerned with the justifications or merits of specific measures from the BEPS Project, nor with assessing the suitability of the ALP for developing states, or considering alternatives or modifications.2 Rather, given that in the current environment developing countries rely on transfer pricing rules as one of their most important mechanisms in countering international tax avoidance, the question is simply concerned with whether the practical task of applying those rules is made easier or harder as a result of the BEPS Project.

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