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The Arm’s Length Principle – An Adequate Means for Taxing Multinational Corporate Groups?
Accounting, Economics and Law: A ConviviumInternational tax law is characterized by the arm’s length principle. However, the arm’s length principle is highly criticized since it is seen as a major driver of tax avoidance.
Anna-Lena Scherer
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Intertax, 2023
The arm’s length principle (ALP) is the cornerstone of multinational enterprises’ (MNEs) profit taxation. However, despite extensive improvements by the OECD’s Base Erosion and Profit Shifting (BEPS) Project, two aspects of the ALP has been widely ...
C. Sureth-Sloane +4 more
semanticscholar +1 more source
The arm’s length principle (ALP) is the cornerstone of multinational enterprises’ (MNEs) profit taxation. However, despite extensive improvements by the OECD’s Base Erosion and Profit Shifting (BEPS) Project, two aspects of the ALP has been widely ...
C. Sureth-Sloane +4 more
semanticscholar +1 more source
World Tax Journal, 2023
The broad nature of the arm’s length principle embedded in article 9 of tax treaties gives rise to various interpretative issues. Even though the transfer pricing rules are drafted to reach an approximate arm’s length result, the open-ended nature of ...
Padwalkar, C. Rodríguez Peña
semanticscholar +1 more source
The broad nature of the arm’s length principle embedded in article 9 of tax treaties gives rise to various interpretative issues. Even though the transfer pricing rules are drafted to reach an approximate arm’s length result, the open-ended nature of ...
Padwalkar, C. Rodríguez Peña
semanticscholar +1 more source
Arm's Length Principle vs. Formulary Apportionment in BEPS Action 13: Stakeholders’ Perspectives
Accounting in Europe, 2023This paper analyses comment-letter lobbying by different stakeholders to influence OECD’s documentation rules on transfer pricing within the Base Erosion and Profit Shifting (BEPS) project.
Z. Akhand, Amin Mawani
semanticscholar +1 more source
International Transfer Pricing Journal, 2022
This article analyses how the Transfer Pricing Guidance for Financial Transactions are implemented in German law and the new Administrative Principles on Transfer Pricing 2021 and in which points they may differ.
T, Prokoph
semanticscholar +1 more source
This article analyses how the Transfer Pricing Guidance for Financial Transactions are implemented in German law and the new Administrative Principles on Transfer Pricing 2021 and in which points they may differ.
T, Prokoph
semanticscholar +1 more source
African Journal of Commercial Studies
The Arm’s Length Principle (ALP), anchored in Article 9 of the OECD Model Tax Convention, remains the cornerstone of global transfer pricing regulation. Yet, its practical application exhibits wide divergence across jurisdictions, shaped by institutional
Victor Mwape +2 more
semanticscholar +1 more source
The Arm’s Length Principle (ALP), anchored in Article 9 of the OECD Model Tax Convention, remains the cornerstone of global transfer pricing regulation. Yet, its practical application exhibits wide divergence across jurisdictions, shaped by institutional
Victor Mwape +2 more
semanticscholar +1 more source
Intertax, 2022
Switzerland continues to be one of the most preferred locations for many businesses when setting up a headquarters or permanent establishment (PE) structures. Thus, obtaining tax certainty and predictability is crucial for such structures.
V. Chand, C. Martin, N. Burkhalter
semanticscholar +1 more source
Switzerland continues to be one of the most preferred locations for many businesses when setting up a headquarters or permanent establishment (PE) structures. Thus, obtaining tax certainty and predictability is crucial for such structures.
V. Chand, C. Martin, N. Burkhalter
semanticscholar +1 more source
African Journal of Commercial Studies
The arm’s length principle (ALP) has long been considered the cornerstone of international transfer pricing regimes. Originating from Article 9 of the OECD Model Tax Convention, the ALP aims to ensure that transactions between related entities reflect ...
Victor Mwape +2 more
semanticscholar +1 more source
The arm’s length principle (ALP) has long been considered the cornerstone of international transfer pricing regimes. Originating from Article 9 of the OECD Model Tax Convention, the ALP aims to ensure that transactions between related entities reflect ...
Victor Mwape +2 more
semanticscholar +1 more source
The Arm's Length Principle in Mitigating Tax Avoidance: A Systematic Literature Review
International Journal of Applied Business and International ManagementThis study examines the effectiveness of Transfer Pricing Documentation (TP Doc) in supporting the Arm’s Length Principle (ALP) to reduce tax avoidance through related-party transactions (RPTs), especially involving tax haven jurisdictions.
I. K. A. Ardika +2 more
semanticscholar +1 more source
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.
Valeria Napadaică
semanticscholar +1 more source