The Concept of “Options Realistically Available” under the OECD Transfer Pricing Guidelines

S. Parekh

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International Transfer Pricing Journal

Article . 2015 . Peer-reviewed

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The Concept of “Options Realistically Available” under the OECD Transfer Pricing Guidelines

descriptionPublicationkeyboard_double_arrow_right Article 03 Sep 2015 English Publisher:IBFDJournal:International Transfer Pricing Journal, volume 22 (issn: 1385-3074, eissn: 2352-9172,

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Authors: S. Parekh;

doi: 10.59403/2knxar8

The Concept of “Options Realistically Available” under the OECD Transfer Pricing Guidelines

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Abstract

The author evaluates the transfer pricing concept of “options realistically available”. The article seeks to understand and analyse the meaning of this concept, identifies various factors that must be analysed to determine the options realistically available and briefly discusses some of the financial management tools and economic theories that can be used to apply this concept in practice.

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	selected citations These citations are derived from selected sources. This is an alternative to the "Influence" indicator, which also reflects the overall/total impact of an article in the research community at large, based on the underlying citation network (diachronically).	12
	popularity This indicator reflects the "current" impact/attention (the "hype") of an article in the research community at large, based on the underlying citation network.	Top 10%
	influence This indicator reflects the overall/total impact of an article in the research community at large, based on the underlying citation network (diachronically).	Top 10%
	impulse This indicator reflects the initial momentum of an article directly after its publication, based on the underlying citation network.	Average