Transfer pricing rules as trade restrictions: Is the OECD’s HTVI approach compatible with the EU fundamental freedoms?
This thesis considers whether the OECD’s HTVI approach is compatible with the EU fundamental freedoms. Its conclusions are of relevance to EU Member States who have implemented, or are looking to implement, the HTVI approach as part of a national transfer pricing regime. Because it is incompatible with the ALP as promulgated by the OECD, the HTVI approach cannot be declared compatible with the fu