The Resource Divergence of third party pricing from arm's length results

Divergence of third party pricing from arm's length results

Label
Divergence of third party pricing from arm's length results
Title
Divergence of third party pricing from arm's length results
Creator
Subject
Language
eng
Summary
Conceptual issues abound in respect of the meaning of "arm's length". While the title of this paper is meant to be provocative, it alludes to certain phenomena that the author believes justify a refinement of the articulation of the arm's length principle. Specifically, this paper focuses on two situations - one involving intercompany financings and one involving cost contribution arrangements - in which, in the author's view, the "right" tax answer is not what one might be led to believe if one simply looked to third-party behaviour. Sandwiched between these discourses is a brief intermezzo on the use and potential misuse of the concept of bargaining power
Citation source
Bound in: Tax polymath : a life in international taxation : essays in honour of John F. Avery Jones. - Amsterdam : IBFD, 2010 ; p. 153-186
http://library.link/vocab/creatorName
Blessing, P.H
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • arm's length principle
  • intercompany transaction
  • cost contribution arrangement
Label
Divergence of third party pricing from arm's length results
Instantiates
Publication
Label
Divergence of third party pricing from arm's length results
Publication

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