“Transfer Pricing: Will the OECD adjust to Reality?” an interesting article released ahead to the Transfer Pricing seminar on 13-15th June, 2012 in Helsinki from Senior Advisor to Tax Justice Network David Spencer. The article discusses how the OECD Transfer Pricing Guidelines are faulty in theory and in practice and that the OECD Guidelines are generally unworkable.

Source: http://www.taxjustice.net/cms/upload/pdf/Spencer_120524_OECD_.pdf