TENDENCIES OF USE OF THE TERM «ARM'S-LENGTH PRICE»
The term «arm's-length price» is regularly used and occupies the
95.440 position in our list of most widely used terms in the
English dictionary.
The map shown above gives the frequency of use of the term «arm's-length price» in the different countries.
Principal search tendencies and common uses of
arm's-length price
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10 ENGLISH BOOKS RELATING TO «ARM'S-LENGTH PRICE»
Discover the use of
arm's-length price in the following bibliographical selection. Books relating to
arm's-length price and brief extracts from same to provide context of its use in English literature.
1
Transfer Pricing and the Arm's
Length Principle in ...
This timely book contains a comparative analysis of the legal basis for the arm's length principle and the contents of the arm's length rules in US tax law as well as in the OECD Model Tax Convention and Transfer Pricing Guidelines.
2
Arm’s
Length Transaction Structures
If, on the other hand, the tax administration determines that no structural
adjustment is authorized, the price agreed in the uncontrolled transactions can
only serve as evidence of the arm's length price in the controlled transaction if the
effects ...
3
Multinational Enterprises and the Global Economy
The arm's-length price is the price two unrelated parties would reach through
bargaining in a competitive market. The best methods rule generally assumes
that the MNE proves that its method of transfer pricing is the closest achievable to
an ...
John H. Dunning, Sarianna M. Lundan, 2008
4
International Commercial Tax
Arm's length pricing The OECD Transfer Pricing guidelines authorise various
methods for establishing an arm's length price. These are usually divided into
three 'traditional transaction methods' and two acceptable 'other methods'. One
pricing ...
Peter Harris, David Oliver, 2010
5
Transfer Pricing Guidelines for Multinational Enterprises ...
... service to increase its profitability, perhaps by complementing its range of
activities. Therefore, it need not always be the case that an arm's length price will
result in a profit for an associated enterprise that is performing an intragroup
service ...
6
International Tax Primer
Chapter Four 63 20 percent on the purchase and sale of products comparable to
the wooden chairs, a 20 percent markup figure might be used in computing the
arm's length price on sales from PCo to SCo. If the final resale price of chairs is
70 ...
Brian J. Arnold, Michael J. McIntyre, 2002
7
Income Tax Regulations (Winter 2009 Edition)
The results derived from applying the comparable uncontrolled price method
generally will be the most direct and reliable measure of an arm's length price for
the controlled transaction if an uncontrolled transaction has no differences with
the ...
CCH Tax Law Editors, Cch, 2008
8
International Taxation of Low-Tax Transactions - High-Tax ...
In addition, the price at which the property is sold (the actual price) must be either
lesser or greater than the arm's-length price. The 'arm's-length price' is the price
which the property mighthavebeen expectedto fetchiftheparties to thetransaction
...
Dennis Campbell, Dennis, Editor Campbell, 2007
9
Transfer Pricing and Customs Valuation: Two Worlds to Tax as One
Under the CUP method, an arm's length price for a controlled sale of tangible
property is equal to the price paid in a comparable uncontrolled transaction.7 The
regulations provide that the CUP method will generally provide the most direct
and ...
Anuschka Bakker, Belema Obuoforibo, 2009
10
The Transfer Pricing of Intangibles
... the promotion of the growth of international trade and investment.49 Although
the opinion of revenue authorities may conflict with that of MNEs regarding the
determination of an arm's length price, the OECD encourages the
acknowledgment ...
5 NEWS ITEMS WHICH INCLUDE THE TERM «ARM'S-LENGTH PRICE»
Find out what the national and international press are talking about and how the term
arm's-length price is used in the context of the following news items.
The OECD's introduction of ex-post evidence could prove difficult in …
... solution to hard-to-value intangibles (HTVI) because of the difficulties many tax authorities have in attributing the arm's-length price, often due ... «Transfer Pricing Week, Jun 15»
Indian government seeks comments on range concept and multiple …
If the transfer price falls outside the above range, the median of the range would be taken as arm's-length price (ALP) and accordingly ... «Transfer Pricing Week, May 15»
Google, Apple and Microsoft defend tax set-up that shifts revenue …
King insisted he did not know what the Australian subsidiary would pay for the iPad, except that it was “an arm's-length price determined in ... «The Guardian, Apr 15»
Spain: Latest developments on transfer pricing legislation in Spain
... and Tax Administrations (OECD guidelines), the CITL eliminates the valuation methodology hierarchy to determine an arm's-length price. «International Tax Review, Mar 15»
Updated: Ohio governor unveils proposed budget for fiscal years …
... however, provide that in the case of sales between related entities, the Tax Commissioner had authority to establish an arm's-length price for ... «Lexology, Feb 15»
