Berries and Boats

And finally the most boring book in the world mixes fruit and ships together.

I must admit, to show my ignorance to the LinkedIn world, that at my age, I did not know what a ‘safe harbour’ was. I discovered it through reading the most boring book in the world. (Note 1)

 Which only goes to show that even when you least expect it you can learn something useful as well as learning an innumerable number of useless concepts and acronyms: comparables, CUPs, MAPs, arm’s length and many others, reading this boring book. Useless to me at any rate.

Not only do they change the meaning of arm’s length, they do it again with ‘safe harbour’.  This is not such a well known expression, but they really massacre the original meaning with their invention of a “bilateral safe harbour MOU.” (Note 2)

No, I don’t know what a bilateral safe harbour MOU is and I have no wish to learn, as I am sure you don’t either. Let’s leave it there, but to add the words ‘bilateral’ and ‘MOU’ to safe harbour is too much to take in, even after analysis.

The introduction of fruit in the book comes from the inclusion of an obscure financial ratio: the berry ratio incorporating it into transfer pricing. (Note 3) Now, I am not being very fair in suggesting that this is fruit related, but it came to mind while reading page 125, probably in the unconscious attempt of my brain to relieve the intense boredom of this paragraph. Berry ratios were devised by an American economist Charles Berry and have nothing to do with berries, straw ones, ras ones or black ones.

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

Note 2: Annex I to Chapter IV, second heading, Page 493 – MOU, here, is a memorandum of understanding

Note 3: Chapter II, Paragraph B.3.5, Page 125