Applying the Arm’s Length Principle to Group Synergies

Journal
Maury, S.
International
International Transfer Pricing Journal 2020 (Volume 27), No. 4
FormatPDF
EUR
40
| USD
45
(VAT excl.)

This article deals with the basic antagonism between group synergies and the arm’s length principle. On the one side, group synergies arise from the interactions between members of a group. On the other side, the arm’s length principle is based on the fiction that members of a group operate separately, as if they were unrelated.