The arms length principle serves as the domestic and international standard to evaluate transfer prices between members of multinational enterprises for tax purposes the oecd has adopted the arms length principle in article 9 of its model income tax convention in order to ensure that transfer prices between members of multinational enterprises correspond to those that would have been agreed . Transfer pricing guidelines the oecd proudly exposes the 1 for a comparative view see jens wittendorff transfer pricing and the arms length principle in international tax law kluwer 2010 pp21 248 ceteris ed guide to international transfer pricing 2010 11 kluwer 2010. The proposed book analyzes the legal basis for the arms length principle and the contents of the principle in us tax law as well as the oecd model tax convention and transfer pricing guidelines it includes a thorough review of international case. Download book transfer pricing arms length principle international tax law series on international taxation ebook series in international taxation in pdf format you can read online transfer pricing arms length principle international tax law series on international taxation ebook series in international taxation here in pdf epub mobi or docx . It is also one of the key elements in international taxation as it allows an adequate allocation of profit taxation rights among countries that conclude double tax conventions through transfer pricing among each other transfer pricing and the arms length principle was one of the focal points of the base erosion and profit shifting beps
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