I have a geunine question for you @MForstater - given your reluctance to categorizing transfer mis-pricing as IFF, what about intra-firm financial methods like thin capialization and derivatives contracts? Should such activities be attempted meassured and accounted for as IFF?
But there are also legitimate disagreements, questions of interpretation, valuation on TP, interest, derivatives where the result might go one way or another but where the details of the transaction itself were not hidden from the revenue (e.g. the BHP/ATO say...)