Results 211 to 220 of about 85,170 (253)

On the European Commission’s Understanding of the Arm’s Length Principle in International Taxation versus State Aid Matters

World Tax Journal, 2021
The European Union is bound to a duty of consistency between its internal policies and external action and a duty of sincere cooperation with its Member States.
S. Castagna
semanticscholar   +1 more source

The EC’s Proposal for a Directive on Transfer Pricing: Paving the Road for a Common Application of the Arm’s Length Principle

International Transfer Pricing Journal, 2023
This article summarizes the key provisions of the EC Proposal for a Directive on Transfer Pricing, highlighting the potential benefits of such Proposal, as well as raising certain issues potentially triggered by its adoption, as well as clarifying the ...
R. Petruzzi, A. Myzithra
semanticscholar   +1 more source

Competencies, Competence and the Arm’s Length Principle

Bulletin for International Taxation, 2023
This article is concerned with competencies and competency assets, a form of intangible asset. The discussion deals primarily with the nature of competency assets, and why they are important in the context of the current income allocation rules, despite ...
R. Collier, I.F. Dykes
semanticscholar   +1 more source

Pillar One, Pillar Two, Transfer Pricing and the Arm’s Length Principle: A Tangled Web of New and Old Taxing Rules

Bulletin for International Taxation, 2023
The OECD Inclusive Framework introduced the Two-Pillar solution – intended to coexist with the current tax framework – to address challenges in an evolving economy. The interaction between the new and old rules may create tensions.
R. Petruzzi, A. Padwalkar
semanticscholar   +1 more source

Intra-Group Financing: Analysis of the Coexistence of the Arm’s Length Principle with the General Anti-Abuse Rules

International Transfer Pricing Journal
The deduction of interest expenses for corporate tax purposes has attracted the attention of tax policymakers and multinational enterprises owing to concerns about base erosion and profit shifting.
D. Sencar, R. Iervolino
semanticscholar   +1 more source

Rules on Intangible Sales – The Real Problem with the Arm’s Length Principle

Bulletin for International Taxation
Profit shifting appears to be driven by underpriced group intangible sales to low-taxed affiliates derived from valuations resulting from income allocation methods.
A. Musselli
semanticscholar   +1 more source

ECJ Decision X BV (C-585/22): Economic Reality or Sham Transaction: May the Arm’s Length Principle and Domestic Anti-Avoidance Provisions Serve the Same Purpose?

International Transfer Pricing Journal
The ECJ decision in X BV (C-585/22) clarified the relationship between the arm's length principle and domestic anti-avoidance provisions in the context of intercompany lending.
M. Adda, F. Parlatore
semanticscholar   +1 more source

The Proposed EU Transfer Pricing Directive and Its Implications for the European Union Single Market: Analysing the Arm’s Length Principle and Associated Enterprise Concept

European Taxation
In this article, the author analyses the “arm’s length principle” and the “associated enterprise” concept, both from a historical perspective, as well as in the context of the proposed EU Transfer Pricing Directive.
C. Pastuszenko
semanticscholar   +1 more source

Peran konsultan pajak dalam penyusunan dokumen transfer pricing berdasarkan arm’s length principle untuk kepatuhan pajak

Jurnal Bisnis Mahasiswa
Penelitian ini menganalisis faktor-faktor pertimbangan konsultan pajak dalam penyusunan dokumen transfer pricing, implementasi arm's length principle, dan kontribusinya terhadap kepatuhan pajak PT X.
O. Kurniawan, Syaiful Rahman Soenaria
semanticscholar   +1 more source

IMPLEMENTATION OF THE ARM'S LENGTH PRINCIPLE IN RELATED PARTY RELATIONSHIPS AT PT S INDONESIA

International Journal of Economics Business and Accounting Research (IJEBAR)
This study aims to analyze the implementation of Arm’s Length Principle by PT S Indonesia in affiliated transactions with SF Co., Ltd, a parent company from Japan.
Rafida Nuraini, Hanung Triatmoko, Oscar Prasetyo Adhi, Asaprima Putra Karunia   +3 more
semanticscholar   +1 more source