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This essay argues that the complete harmonisation of transfer pricing rules with the arm’s length principle is unattainable for three reasons. First, states are not under a legal obligation to apply the principle outside of treaty or domestic law. Second, the theoretical shortcomings of the principle are creating a divergence from the OECD guidelines on how the principle should be applied. Third, the perception held by states that multinational enterprises are not paying a fair share of tax is also creating a divergence from the OECD guidelines on the principle. The resultant divergence is a significant obstacle to transfer pricing harmonisation.

The Harmonisation of Transfer Pricing: the Obstacles, the Arm's Length Principle and the OECD Guidelines