The Resource The arm's length standard and tax justice : reflections on the present and the future of transfer pricing

The arm's length standard and tax justice : reflections on the present and the future of transfer pricing

Label
The arm's length standard and tax justice : reflections on the present and the future of transfer pricing
Title
The arm's length standard and tax justice : reflections on the present and the future of transfer pricing
Creator
Subject
Language
  • eng
  • eng
Summary
The aim of this contribution is to analyse the arm's length standard from a tax justice perspective so as to determine the proper breadth of the fiction it imposes. To that end, an interpretative solution is proposed to minimize negative outcomes derived from the alleged shortcomings of the mentioned standard that mainly arise due to the fact that MNEs do not operate in markets as independent parties do. Although the proposal may seem rather theoretical or abstract, practical implications may be derived from it in diverse matters within transfer pricing, e.g. on the recognition of profits derived from active and passive association, on how synergistic gains should be split, on the scope of transactional adjustments and on the fostering of two-sided analysis. In fact, the proposal may serve to provide a sound and strong theoretical basis to encourage the proposals discussed within the BEPS Project
Citation source
In: World tax journal. - Amsterdam. - Vol. 10 (2018), no. 3 ; p. 351-379
http://library.link/vocab/creatorName
Navarro Ibarrola, A
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • arm's length principle
  • transfer pricing
  • horizontal equity
  • ability to pay
  • transfer pricing adjustment
Label
The arm's length standard and tax justice : reflections on the present and the future of transfer pricing
Instantiates
Publication
Note
20180824
Other control number
wtj_2018_03_int_2.html
Label
The arm's length standard and tax justice : reflections on the present and the future of transfer pricing
Publication
Note
20180824
Other control number
wtj_2018_03_int_2.html

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