Reflections on Business Profits and the Arm’s-Length Principle

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

38 Pages Posted: 19 Nov 2010  

Richard J. Vann

The University of Sydney Law School

Date Written: November 17, 2010

Abstract

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

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

Richard J. Vann (Contact Author)

The University of Sydney Law School ( email )

Faculty of Law Building, F10
The University of Sydney
Camperdown, NSW 2006
Australia
+61 2 9351 0206 (Phone)
+ 61 2 9351 0200 (Fax)

HOME PAGE: http://www.law.usyd.edu.au/about/staff/RichardVann/index.shtml

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