Gary Richards and Robert Hartley (Mishcon de Reya) focus on how OECD’s public consultation document on the ‘unified approach’ under pillar one sheds light on the future scope of the arm’s length principle.
At first sight the OECD’s Secretariat proposal for a ‘unified approach’ under pillar one – set out in its public consultation document (PCD) (see bit.ly/31Idzbm) – might suggest the answer to the question is no. However a closer reading of the PCD suggests that in reality the ALP or at least its scope is becoming increasingly circumscribed either by OECD guidance itself or by the application (or non-application) of the principle.
The ALP
Much ink has been spent describing the principle let alone on how to apply those principles to transactions into which parties acting at arm’s length would be unlikely to enter. Suffice to...
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Gary Richards and Robert Hartley (Mishcon de Reya) focus on how OECD’s public consultation document on the ‘unified approach’ under pillar one sheds light on the future scope of the arm’s length principle.
At first sight the OECD’s Secretariat proposal for a ‘unified approach’ under pillar one – set out in its public consultation document (PCD) (see bit.ly/31Idzbm) – might suggest the answer to the question is no. However a closer reading of the PCD suggests that in reality the ALP or at least its scope is becoming increasingly circumscribed either by OECD guidance itself or by the application (or non-application) of the principle.
The ALP
Much ink has been spent describing the principle let alone on how to apply those principles to transactions into which parties acting at arm’s length would be unlikely to enter. Suffice to...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
