Contemporary application of the arm's length principle in transfer pricing / Marta Pankiv.
This book outlines how the application of the arm?s length principle should be reconsidered in light of the initiative of the OECD and G20 to counter tax base erosion and profit shifting (BEPS). The arm?s length principle embedded in article 9 of the OECD Model is not an anti-avoidance rule and has...
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| Online Access: |
Full Text (via EBSCO) |
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| Main Author: | |
| Format: | eBook |
| Language: | English |
| Published: |
Amsterdam :
IBFD,
[2017]
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| Series: | WU Institute for Austrian and International Tax Law European and international tax law and policy series ;
v. 6. |
| Subjects: |
| Summary: | This book outlines how the application of the arm?s length principle should be reconsidered in light of the initiative of the OECD and G20 to counter tax base erosion and profit shifting (BEPS). The arm?s length principle embedded in article 9 of the OECD Model is not an anti-avoidance rule and has been misidentified as the primary tool for tackling abusive practices. Transfer pricing analysis, commonly understood as examining economic substance, in reality examines whether related parties have the functional and financial capacity to perform the contracts they have entered into. |
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| Physical Description: | 1 online resource (xvi, 242 pages) |
| Bibliography: | Includes bibliographical reference (pages 215-242). |
| ISBN: | 9789087224141 9087224141 |
| ISSN: | 2451-8360 ; |
| Source of Description, Etc. Note: | Print version record. |