PDF At Arms Length

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The number and location of users will serve as an allocation key, but there are risks that this could end up being a blunt tool.

Mellor - Arms Length

It would potentially hit traditional TP arrangements hard. Companies with structures in places like Ireland and the Netherlands could face challenges to justify their practices.

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This could potentially open up a new level of risk and uncertainty for taxpayers. Where MNEs operate locally through subsidiaries, market jurisdictions might seek to wage a tax claim on the income of such multinationals. But such MNEs working with local businesses on a contractual basis are unlikely to see their profits re-allocated to that jurisdiction.


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It is possible that formulary apportionment could apply to certain transactions and not others. This would create a dual set of approaches to transfer pricing. It would still be a tremendous shift in international tax.

The result for taxpayers would be more complexity and more risk. The preference for a multilateral solution clears the way to oppose unilateral action. Many European countries are, meanwhile, rushing to find a workable levy on the digital economy. Austria, France, the UK and Spain have approved proposals or are planning to impose special measures against the high-tech sector. This would be a reversal of fortunes.

The future of the arm’s-length principle

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All rights reserved. Relations between the bank and the committee will be at arm's length until the report is delivered in July. Easy Learning Idioms Dictionary.

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Nearby words of 'at arm's length'. Related Terms of 'at arm's length'. Definition of at arm's length from the Collins English Dictionary. Quick word challenge. He used to be part of a rap group. He used to be part of a wrap group. Would you like some tea?

Arm's length standard | Deloitte | Tax | News

Julie has worked as a tax journalist and editor for more than 13 years. Prior to that, she worked as an in-house tax attorney in New York. It should not be acted upon without legal advice accounting for a particular situation.

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