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The Harmonisation of Transfer Pricing: the Obstacles, the Arm's Length Principle and the OECD Guidelines

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posted on 14.11.2021, 00:53 by Timms, Duran

This essay argues that the complete harmonisation of transfer pricing rules with the arm’s length principle is unattainable for three reasons. First, states are not under a legal obligation to apply the principle outside of treaty or domestic law. Second, the theoretical shortcomings of the principle are creating a divergence from the OECD guidelines on how the principle should be applied. Third, the perception held by states that multinational enterprises are not paying a fair share of tax is also creating a divergence from the OECD guidelines on the principle. The resultant divergence is a significant obstacle to transfer pricing harmonisation.

History

Copyright Date

01/01/2013

Date of Award

01/01/2013

Publisher

Victoria University of Wellington - Te Herenga Waka

Rights License

Author Retains Copyright

Degree Grantor

Victoria University of Wellington - Te Herenga Waka

ANZSRC Type Of Activity code

970118 Expanding Knowledge in Law and Legal Studies

Victoria University of Wellington Item Type

Research Paper or Project

Language

en_NZ

Victoria University of Wellington School

School of Law