Results 11 to 20 of about 615 (239)
The arm's length principle and tacit collusion [PDF]
International Journal of Industrial Organization, 2013 The arm's length principle states that the transfer price between two associated enterprises should be the price that would be paid for similar goods in similar circumstances by unrelated parties dealing at arm's length with each other. This paper examines the effect of the arm's length principle on dynamic competition in two alternative models of ...
Choe, Chongwoo, Matsushima, Noriaki
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Duopolistic Competition, Taxes and the Arm's-Length Principle [PDF]
SSRN Electronic Journal, 2005 Numerous (high-tax) countries presume that multinational firms use their transfer-pricing policies to shift profits into countries with lower tax rates. To avoid the corresponding loss in tax revenues, tax authorities develop constantly tightening rules which limit the scope of transfer-price distortions.
Korn, Evelyn, Lengsfeld, Stephan
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Fairness and the Arm's Length Principle in a Digital Economy [PDF]
SSRN Electronic Journal, 2018 Die OECD Base Erosion Profit Shifting (BEPS) Initiative sowie die aktuelle Fairness orientierte öffentliche Diskussion zur Besteuerung digitaler Geschäftsmodelle verdeutlichen die Bedeutung und Komplexität des Fremdvergleichsgrundsatzes. Wir modellieren einen international fragmentierten Produktionsprozess eines digitalen Gutes und zeigen wie Fairness ...
Greil, Stefan +2 more
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Beyond the Arm's Length Principle
, 2021 The arm's length principle and the notion of permanent establishment are the two pillars of international corporate tax. Drafted in 1920, they are now under the fire of acute criticism and they appear to have become obsolete: they are unable to face the challenges of a global and digital economy.
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The distorting arm's length principle. [PDF]
, 2009 To prevent profit shifting by manipulation of transfer prices, tax authorities typically apply the arm's length principle in corporate taxation and use comparable market prices to `correctly' assess the value of intracompany trade and royalty income of multinationals.
Devereux, Michael P. +1 more
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Соціальна економіка, 2022 The purpose of the study is to assess the possibility of combining the concepts of transfer pricing, beneficial owner of income and valid business purpose in a model of three-component tax risk assessment for countering BEPS. To achieve this purpose, the
Dmytro Nosenko
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Transfer Pricing Methods for Services and the Policy of Fixed Length Principle
Economics and Business, 2019 The paper deals with the methods used by companies for controlled transactions in services. The author performs an analysis of the ways a company that takes part in controlled transactions of transfer pricing can tackle tax issues using an adequate tax ...
Challoumis Constantinos
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Transfer pricing and safe harbours
Acta Universitatis Agriculturae et Silviculturae Mendelianae Brunensis, 2013 Transfer prices are significant for both taxpayers and tax administrations because they determine in large part taxable profits of associated enterprises in different tax jurisdictions.
Veronika Solilová
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Nordicom Review, 2021 This article describes the historical development of media policy in Greenland, and the shifts in the underlying normative and causal ideas that legitimise media policy.
Ravn-Højgaard Signe
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In Principle, (Im)possible: Harmonizing an EU Arm’s Length Principle
EC Tax Review, 2023 The arm’s length principle should maintain a tax-level playing field between multinational groups of taxpayers and standalone enterprises. Despite the fact that all EU Member States implemented an arm’s length principle in their domestic transfer pricing rules, differences in the application of the arm’s length principle remain.
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