The Resource Business risk allocation : the outermost boundary of the arm's length principle and the Amazon case

Business risk allocation : the outermost boundary of the arm's length principle and the Amazon case

Label
Business risk allocation : the outermost boundary of the arm's length principle and the Amazon case
Title
Business risk allocation : the outermost boundary of the arm's length principle and the Amazon case
Creator
Subject
Language
eng
Summary
This article successively considers: investment planning, tax planning, and the arm?s length principle; intangibles already developed, intangibles possibly to be developed, and the arm?s length principle; the limits of the arm?s length principle in preventing the development of intangibles outside high-tax jurisdictions; an example of a unilateral action by a high-tax jurisdiction to protect its tax base: the U.S. Global Intangible Low-Taxed Income (GILTI) provision; empirical evidence of business risk allocation as a method of shifting profits into low-tax jurisdictions; the OECD reaction to the allocation of business risk to low-tax jurisdictions; and an analysis of the effects of the new legislative principles in the Amazon case, which lies at the boundary of the arm?s length principle. The author finally concludes
Citation source
In: International tax journal. - Riverwoods. - Vol. 44 (2018), no. 5 (September-October) ; p. 7-15
http://library.link/vocab/creatorName
Musselli, A
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • tax planning
  • risk
  • arm's length principle
  • case law
  • intangibles
  • GILTI
  • profit shifting
  • transfer pricing
Label
Business risk allocation : the outermost boundary of the arm's length principle and the Amazon case
Instantiates
Publication
Label
Business risk allocation : the outermost boundary of the arm's length principle and the Amazon case
Publication

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