Contemporary Application of the Arm's Length Principle in Transfer Pricing

Released on by Marta Pankiv
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  • Contemporary Application of the Arm's Length Principle in Transfer Pricing Book Detail

  • Author : Marta Pankiv
  • Release Date : 2017
  • Publisher :
  • Genre : International business enterprises
  • Pages : 242
  • ISBN 13 : 9789087224134
  • File Size : 80,80 MB
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Contemporary Application of the Arm's Length Principle in Transfer Pricing by Marta Pankiv PDF Summary

Book Description: 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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Fundamentals of Transfer Pricing

Fundamentals of Transfer Pricing

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Transfer pricing is one of the most relevant and challenging topics in international taxation. Over the last century, nearly every country in the world introduc