Add to ORKGMultinational enterprises (MNEs) operating by way of wholly owned subsidiaries are responsible for an increasing percentage of global trade. This paper looks at how the existing rules based on the arm’s length principle allocate a MNE’s profit between the taxing jurisdictions in which it operates. It highlights the limitations of the arm’s length principle by reference to a centralised intangible asset model and prior academic literature. This paper then examines in greater detail how the arm’s length principle deals with MNE economic rent. The paper looks at the sources of economic rent in general, and then examines in detail the impact on economic rent of operating as a MNE by way of controlled subsidiaries rather than through independent...
To prevent profit shifting by manipulation of transfer prices, tax authorities typically apply the a...
The current profit allocation framework, i.e. the arm’s length standard, is mainly based on a facts ...
In the current globalized and knowledge-based economy, intellectual property (IP) and intangible ass...
The arm’s length principle has been the allocation rule for income between associated enterprises fo...
To prevent profit shifting by manipulation of transfer prices, tax authorities typically apply the a...
To prevent profit shifting by manipulation of transfer prices, tax authorities typically apply the a...
To prevent profit shifting by manipulation of transfer prices, tax authorities typically apply the a...
This thesis is based on the regulations found in the OECD model and the OECD TP guidelines concernin...
Profit shifting due to manipulation of transfer prices erodes the corporate tax base in high tax cou...
To prevent profit shifting by manipulation of transfer prices, tax authorities typically apply the a...
The arm’s length principle has now been for almost eighty years the basis for business income alloca...
The profit split method in its current form is a relatively new part of the OECD transfer pricing gu...
This article examines the current transfer pricing regime to consider whether it is a sound model to...
When multinational enterprises (MNEs) separate the geographical location of affiliates, they can shi...
International taxation is concerned mainly with the equitable allocation of cross-border income betw...
To prevent profit shifting by manipulation of transfer prices, tax authorities typically apply the a...
The current profit allocation framework, i.e. the arm’s length standard, is mainly based on a facts ...
In the current globalized and knowledge-based economy, intellectual property (IP) and intangible ass...
The arm’s length principle has been the allocation rule for income between associated enterprises fo...
To prevent profit shifting by manipulation of transfer prices, tax authorities typically apply the a...
To prevent profit shifting by manipulation of transfer prices, tax authorities typically apply the a...
To prevent profit shifting by manipulation of transfer prices, tax authorities typically apply the a...
This thesis is based on the regulations found in the OECD model and the OECD TP guidelines concernin...
Profit shifting due to manipulation of transfer prices erodes the corporate tax base in high tax cou...
To prevent profit shifting by manipulation of transfer prices, tax authorities typically apply the a...
The arm’s length principle has now been for almost eighty years the basis for business income alloca...
The profit split method in its current form is a relatively new part of the OECD transfer pricing gu...
This article examines the current transfer pricing regime to consider whether it is a sound model to...
When multinational enterprises (MNEs) separate the geographical location of affiliates, they can shi...
International taxation is concerned mainly with the equitable allocation of cross-border income betw...
To prevent profit shifting by manipulation of transfer prices, tax authorities typically apply the a...
The current profit allocation framework, i.e. the arm’s length standard, is mainly based on a facts ...
In the current globalized and knowledge-based economy, intellectual property (IP) and intangible ass...