Extract to table

To the extent the 2022 revisions provide additional guidance on risk assumption and control — including the requirement that an entity claiming entitlement to risk-related returns must exercise decision-making control over those risks and have the financial capacity to bear them — these provisions reinforce the analysis under the 2017 edition

However, the OECD framework imposes an important constraint on such reallocation: the IRS must demonstrate that PPC's projections were unreasonable at the time they were made, not merely that different assumptions would produce different results

The OECD Guidelines do not prescribe a specific WACC or specific revenue growth rate, recognizing that these inputs are matters of economic judgment that must be assessed in light of the specific facts and circumstances of each transaction

A participant must exercise control over the specific risks it assumes through its participation in the arrangement and must have the functional capability to exercise such control

The best method rule provides that the arm's-length result of a controlled transaction must be determined under the method that, given the facts and circumstances, provides the most reliable measure of an arm's-length result