International - The New Interpretation of the Arm’s Length Principle: A Post-BEPS Evaluation
- M. Heggmair
- International Transfer Pricing Journal, 2017 (Volume 24), No 4
- 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.