Transfer Pricing and the Arm's Length Principle in International Tax Law (Hardcover)

The arm's length principle serves as the domestic and international standard toevaluate transfer prices between members of multinational enterprises for taxpurposes. The OECD has adopted the arm's length principle in Article 9 of itsModel Income Tax Convention in order to ensure that transfer prices betweenmembers of multinational enterprises correspond to those that would have beenagreed between independent enterprises under comparable circumstances. Thearm's length principle provides the legal framework for governments to have theirfair share of taxes, and for enterprises to avoid double taxation on their profits.