Reflections on Business Profits and the Arm’s-Length Principle
Richard J. Vann
University of Sydney - Faculty of Law; Centre for International Finance and Regulation (CIFR)
November 17, 2010
THE TAXATION OF BUSINESS PROFITS UNDER TAX TREATIES, pp. 133-169, B.J. Arnold, J. Sasseville, E.M. Zolt, eds., Canadian Tax Foundation, 2003
Sydney Law School Research Paper No. 10/127
This paper considers the structure of the transfer pricing rules in tax treaties and their modern development in the Transfer Pricing Guidelines. It discusses how tax structuring and restructuring relying on the guidelines occurred to reduce residence and source taxation and commences an analysis of the fault lines in the transfer pricing rules in order to consider possible changes to the approach to transfer pricing.
Number of Pages in PDF File: 38
Keywords: Business Restructures, Corporate Taxation, Double Taxation, International Taxation, Permanent Establishment, Residence, Transfer Pricing, Tax Treaties
JEL Classification: K10, K30, K33, K34Accepted Paper Series
Date posted: November 19, 2010
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