Anmerkungen:
In: Lorraine Eden. 2020. "David and the Three Goliaths - Defending the Arm's Length Principle", Transfer Pricing Report (Sept. 14). Tax Management International Journal (Oct 2). Reproduced with permission. Copyright R 2020 The Bureau of National Affairs, Inc. 800-372-1033
Nach Informationen von SSRN wurde die ursprüngliche Fassung des Dokuments 2020 erstellt
Beschreibung:
The arm's length principle (ALP), which requires multinationals to price their related-party transactions as if the transactions were conducted at arm's length, currently faces three major criticisms (or Goliaths), two old, one new. The old Goliaths are (1) transfer pricing is abusive and strips income out of developing countries; and (2) transfer price cannot work either in theory or practice due to the absence of comparables and the presence of synergies. The new Goliath is that the ALP cannot work in the digital economy. I argue that all three Goliaths can be felled by the ALP (David) using the arrows of logic, economics, and pragmatism. The ALP is still and needs to remain a valuable core component of the international tax system