Results 261 to 270 of about 14,190 (298)

Stateless Income, State Aid and the (Which?) Arm’s Length Principle

Intertax, 2016
The 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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The Constitutional Implications of an EU Arm’s Length Principle

European Taxation, 2020
A 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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Transfer Pricing and the Arm's Length Principle After BEPS

2017
Abstract This book examines the transfer pricing rules, including the arm's length principle (ALP), in the context of the G20 / OECD Base Erosion and Profit Shifting (BEPS) project. It considers the nature and scope of the transfer pricing rule starting with an explanation of how and on what basis the rules were created.
Richard Collier, Joseph L Andrus
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The arm's length principle, transfer pricing, and location choices

Journal of Economics and Business, 2013
Abstract 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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Post-BEPS Application of the Arm’s Length Principle to Intangibles Structures

International Transfer Pricing Journal, 2016
The 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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Reflecting on the “Arm’s Length Principle”: What is the “Principle”? Where Next?

2012
The “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 European Commission’s Arm’s Length Standard: Relationship and Compatibility with the Arm’s Length Principle under Transfer Pricing

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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Arm's Length Principle and Fix Length Principle Mathematical Approach

SSRN Electronic Journal, 2018
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Applying the Arm’s-Length Principle

2017
Joel Cooper, Randall Fox, Jan Loeprick, Komal Mohindra   +3 more
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Transfer pricing and the Arm's length principle

2008
The Diploma Thesis is devoted to the Transfer pricing problematic, whereby the Transfer Pricing and the Arm's length principle as such are defined, further the Czech and Slovak transfer pricing law is presented and the different transfer pricing together with their possible usage are described.
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