Mr Treidler welcomes TPED framework and comments that “the TPED proposal should be incorporated into the existing OECD transfer pricing guidelines”. He finds that the “framework proposed by TPED has the potential to facilitate a more pragmatic application of the arm’s length principle” and is “highly sensible”.
Mr Treidler questions whether TPED framework can contribute to current discussions taking place at the OECD on the envisaged international tax reform covering digital and consumer facing business models.
We note that Mr Treidler’s position is rather vis-à-vis the OECD reform itself than against the possible use of the TPED’s framework in the current discussions, provided that TPED’s framework leads to arm’s length results.
TPED thanks warmly Mr Treidler for taking the time to review and comment our propositions. His comments are thorough and helpful.