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International - Transactions with Hard-to-Value Intangibles: Is BEPS Action 8 Based on the Arm’s Length Principle?

Country:
International
Author:
O. Fedusiv
Issue:
International Transfer Pricing Journal, 2016 (Volume 23), No 6
Published:
17 October 2016
Action 8 claims that the ex post approach is consistent with the arm’s length principle. Based on his analysis in this article, however, the author concludes that the ex post approach may deviate from the arm’s length principle and, consequently, lead to economic double taxation.
 
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