Transfer Pricing in the Arm’s Length Standard and BEPS 2.0

Write a paper in the area of Transfer Pricing in The Arm’s Length Standard and BEPS 2.0 – where does the Arm’s Length Standard go from here.
The constraints of the paper are as follows:
1. It must relate to Transfer Pricing
2. You provide an Hypothesis statement on what you will prove (I recommend discussing the Hypothesis statement with me.)
3. Describe the transaction being analyzed/discuss or how the hypothesis relates to transfer pricing. That is, what transfer pricing issue are you researching and how it relates to the class.
4. Your paper should include tax/transfer pricing references and tax nomenclature.