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International - The New Interpretation of the Arm’s Length Principle: A Post-BEPS Evaluation

Country:
International
Author:
M. Heggmair
Issue:
International Transfer Pricing Journal, 2017 (Volume 24), No 4
Published:
3 July 2017
In this article, the author discusses the interpretation of the arm’s length principle, as defined by the OECD in the BEPS Actions 8-10 Final Reports, with a focus on the substance-over-form principle and the consequences for the tax authorities to apply the required economic review and analysis of the business model and the transfer pricing arrangements.
 
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