Results 221 to 230 of about 85,170 (253)

Unmasking Transfer Pricing Manipulation in Zambia’s Copper Mining Sector: An Analysis of Schemes, Legal Gaps, and Enforcement Challenges under the Arm’s Length Principle

East African Finance Journal
This article interrogates the pervasive use of transfer pricing manipulation (TPM) schemes by multinational enterprises (MNEs) operating in Zambia’s copper mining industry, examining the legal, institutional, and economic ramifications of such practices.
Victor Mwape, Munyonzwe Hamalengwa, Austin Mwange   +2 more
semanticscholar   +1 more source

Evaluating the Arm’s Length Principle in Fiscal Corrections for Intragroup Services: Evidence from the Federal Karyatama-EMAPPL Case

Siyasah Dusturiyah: State Law Review
This study aims to analyze the compatibility between Indonesian domestic norms and the OECD Transfer Pricing Guidelines in the application of the arm's length principle (ALP) on the verification of cross-jurisdictional management service costs.
N. Kartiko, Alex Oktobertus, Pandapotan Gultom   +2 more
semanticscholar   +1 more source

Perspectives and Future Prospects of the Arm's Length Principle at EU Level Considering the Proposed European Transfer Pricing Directive (Part One)

Bulletin for International Taxation
This two-part article examines the arm’s length principle from a European perspective. Part One analyses the implications resulting from the 2023 EU Directive on transfer pricing as well as its possible replacement by an EU TP Platform.
J. Calderón Carrero
semanticscholar   +1 more source

Why the Arm’s Length Principle Should Be Maintained

International Transfer Pricing Journal, 2020
The OECD’s so-called “Pillar One Proposal” partly overrules the arm’s length principle. The authors argue that this is a step in the wrong direction.
U. Schreiber, D. Simons, S. Greil, M. Lagarden   +3 more
semanticscholar   +1 more source

Tax law disputes over the arm’s length principle in affiliated share transfers

Corporate Law & Governance Review
Affiliated share transfer transactions pose significant challenges in corporate law and governance, particularly when they trigger tax disputes over compliance with the arm’s length principle [ALP] (Mwape et al., 2025).
Bembo Syah Sutan Irham Agung, S. Nuryanah   +1 more
semanticscholar   +1 more source

Determinant Tax Payer Substantiive Compliance, Arm's Length Principle Moderation Business Fairness Principle: Fair Price Transfers Become Sustainable Mne Company

Social Science Research Network
This study adopts an integrated conceptual and empirical approach to examine substantive tax compliance among multinational enterprises (MNEs), defined as tax reporting and payment behavior that adheres to the intent rather than merely the formal ...
Sartono Suwarno
semanticscholar   +1 more source

Transfer Pricing and the Arm's Length Principle After BEPS

, 2017
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
J. Andrus, R. Collier
semanticscholar   +1 more source

Perspectives and Future Prospects of the Arm's Length Principle at EU Level Considering the Proposed European Transfer Pricing Directive (Part Two)

Bulletin for International Taxation
In this article, the author continues to examine the 2023 European proposal on transfer pricing and multinational taxation, noting its misalignment with global efforts.
J.M. Calderón
semanticscholar   +1 more source

Rethinking the Arm’s Length Principle and Its Impact on the IP Licence Model after OECD/G20 BEPS Actions 8-10: Nothing Changed But the Change?

World Tax Journal, 2019
Tax planning involving intangibles has become a major concern among governments, revenue authorities, media, the general public and international organizations. Multinational enterprises have been perceived to be able to shift profits by transferring and
M. Screpante
semanticscholar   +1 more source

Advocate General’s Opinions in the X BV Case (C-585/22) – Exploring the Potential Interaction between Wholly Artificial Arrangements and the Arm’s Length Principle – Convergency or Divergency?

International Transfer Pricing Journal
The proper characterization of the arm’s length principle (ALP) still represents an unresolved issue in the context of EU tax law since it is not clear whether it represents a rule on allocation of income aimed at avoiding economic double taxation or if ...
M. Adda, U. Lorenzi
semanticscholar   +1 more source