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BEFIT – Is the Arm’s Length Principle Still Fit for Purpose?
International Transfer Pricing Journal, 2021On 18 May 2021, the European Commission issued a press release announcing an ambitious new project: the creation of a business taxation framework that would be both suitable and sustainable for the 21st century. Embedded in this project was an outline of the Business in Europe: Framework for Income Taxation, or “BEFIT” proposal.
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Reflecting on the “Arm’s Length Principle”: What is the “Principle”? Where Next?
2012The “arm’s length principle,” is fundamentally antithetical to the economic, commercial and business characteristics of the taxpayers whose relations with each other within commonly controlled groups it is meant to evaluate and discipline. This collision has always been embedded in the “principle” but is becoming more prominent and disruptive in ...
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The Constitutional Implications of an EU Arm’s Length Principle
European Taxation, 2020A question that has arisen in the cases concerning tax rulings that have been brought by the European Commission is whether or not the arm’s length principle is an autonomous standard under EU law. This article seeks to explain why there is no autonomous EU arm’s length principle, or, if there were one, that this would have profound constitutional ...
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International Transfer Pricing Journal, 2020
Traditionally, the arm’s length principle relies on three pillars: the separate entity principle, the relevance of contractual arrangements and the comparability of the transaction. The purpose of this article is to show that, with the BEPS program and Pillars One and Two, new pillars have emerged in the form of allocation keys and safe harbours.
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Traditionally, the arm’s length principle relies on three pillars: the separate entity principle, the relevance of contractual arrangements and the comparability of the transaction. The purpose of this article is to show that, with the BEPS program and Pillars One and Two, new pillars have emerged in the form of allocation keys and safe harbours.
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Stateless Income, State Aid and the (Which?) Arms Length Principle
Intertax, 2016The arm’s length principle has a new function. When used by the European Union (EU) Commission for State aid control purposes, it is aimed at protecting a level playing field for all economic operators in the internal market, i.e. at protecting free competition, rather than at tax base protection or prevention of double taxation.
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Post-BEPS Application of the Arm’s Length Principle to Intangibles Structures
International Transfer Pricing Journal, 2016The arm’s length principle, as embedded in article 9 of the OECD Model Convention, is not an anti-avoidance rule and has been misidentified as the primary tool to tackle certain abusive behaviours of multinational enterprises. This article refers to the new OECD guidelines on intangibles as background and provides an overview of the new approaches to ...
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Transfer pricing issues - the arm's length principle
Development Through Research and Innovation IDSC-2025As the globalization process and international trade has taken off, the number of multinational groups significantly increased. Especially for the past century. In this regard, it is important to address the consequences for the MNEs as well as for national tax authorities.
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International Transfer Pricing Journal, 2018
The European Commission’s Decisions on State aid have sparked an international uproar, especially in regard of the Commission’s methodology and conclusions. In this article, the author seeks to provide insight into the Commission’s most contentious and sustained pronouncement, namely that an autonomous arm’s length standard is embedded within the main ...
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The European Commission’s Decisions on State aid have sparked an international uproar, especially in regard of the Commission’s methodology and conclusions. In this article, the author seeks to provide insight into the Commission’s most contentious and sustained pronouncement, namely that an autonomous arm’s length standard is embedded within the main ...
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The arm's length principle, transfer pricing, and location choices
Journal of Economics and Business, 2013Abstract This paper examines the impacts of the arm's length principle on tax revenues under endogenous location choices. The results show that the level of transfer price depends not only on taxation policies, but also on firms’ location choices. An imposition of the arm's length principle on a multinational enterprise does not raise tax revenues ...
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Arm's Length Principle and Fix Length Principle Mathematical Approach
SSRN Electronic Journal, 2018openaire +1 more source