Contemporary Application of the Arm's Length Principle in Transfer Pricing

Download or read book Contemporary Application of the Arm's Length Principle in Transfer Pricing written by Marta Pankiv and published by . This book was released on 2017 with total page 242 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book outlines how the application of the arm?s length principle should be reconsidered in light of the initiative of the OECD and G20 to counter tax base erosion and profit shifting (BEPS). The arm?s length principle embedded in article 9 of the OECD Model is not an anti-avoidance rule and has been misidentified as the primary tool for tackling abusive practices. Transfer pricing analysis, commonly understood as examining economic substance, in reality examines whether related parties have the functional and financial capacity to perform the contracts they have entered into.