Formulaic (or Formulary?!) Apportionment Wearing Value Creation Clothes: Is the Wolf Dressed in Sheep´s Clothing?
Nothing changed but the change Despite several changes were introduced to Chapter I and Chapter VI of the 2017 OECD Guidelines on intangibles in accordance with Actions 8-10 BEPS Final Reports to align taxing rights and value creation, those changes were not substantial to permit an application of the ALP that will prevent profit shifting…