Arms and thumbs

For the last few weeks, I have been wondering how to write about the most boring book in the world without being boring myself!  It is complicated but here is my first try.

The authors are into arms and thumbs. Take this short sentence from page 95:

“Accordingly, a rule of thumb cannot be used to evidence that a price or an arrangement of income is arm’s length.”  (Note 2)

It’s a pity they are inconsistent. They should either use ‘thumb’s rule’ with ‘arm’s length’ or ‘rule of thumb’ with ‘length of an arm’, and not mix up the expressions. It makes it untidy and rather unwieldy!

And then they bring in cups, not saucers and not mugs, but as they call them CUP, always in capitals. Arms and thumbs come in Chapter 1 and then cups are introduced in Chapter 2. This acronym was perhaps introduced to lighten the atmosphere a little because by Chapter 2 the book is getting difficult to read.

I should admit now though, their cup has nothing to do with tea or any other hot drink. CUP in this environment means ‘Comparable Uncontrolled Price’ whatever that means. This expression on its own shows clearly how boring the whole subject is. And then if you go back to the sentence above what on earth is an ‘arrangement of income.’ I have no idea at all and even if I did I would not bore you with an explication or definition.

They also throw in a similar one to the CUP. They have invented a MAP which is not a map at all. A MAP is a Mutual Agreement Procedure. Of course!

Note 1: The most boring book in the world is ‘OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations’, January 2022 *

Note 2: Chapter II, Section A, Paragraph 2.10, Page 95

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