THE TAXATION OF BUSINESS PROFITS UNDER TAX TREATIES, pp. 133-169, B.J. Arnold, J. Sasseville, E.M. Zolt, eds., Canadian Tax Foundation, 2003
38 Pages Posted: 19 Nov 2010
Date Written: November 17, 2010
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.
Keywords: Business Restructures, Corporate Taxation, Double Taxation, International Taxation, Permanent Establishment, Residence, Transfer Pricing, Tax Treaties
JEL Classification: K10, K30, K33, K34
Suggested Citation: Suggested Citation
Vann, Richard J., Reflections on Business Profits and the Arm’s-Length Principle (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. Available at SSRN: https://ssrn.com/abstract=1710945