This book examines the authority to restructure and to disregard controlled transactions based on the arm's length principle. The book, thus, examines the outer limits of the adjustment …

The common theme of the two main issues can be formulated as the question of how broad the authority is that the arm's length principle grants to domestic tax administrations. This study, …

2018年4月15日 · Arm’s Length Transaction Structures: Recognizing and restructuring controlled transactions in transfer pricing (IBFD Doctoral Series Book 20) - Kindle edition by Bullen, …

The two - highly interrelated - main issues addressed by the book are to what extent domestic tax administrations, for transfer pricing purposes, are required to recognize and to what extent they...

2011年4月1日 · This study, thus, examines the outer limits of the adjustment authority granted by the arm’s length principle. Arm’s Length Transaction Structures examines these issues in the …

2011年1月1日 · This book examines the authority to restructure and to disregard controlled transactions based on the arm's length principle. The book, thus, examines the outer limits of …

Download Citation | On Mar 31, 2011, Andreas Bullen published Arm’s Length Transaction Structures | Find, read and cite all the research you need on ResearchGate

Semantic Scholar extracted view of "Arm ’ s length transaction structures : Recognising and restructuring controlled transactions in transfer pricing – Summary –" by Andreas Bullen

2011年1月1日 · This book examines the authority to restructure and to disregard controlled transactions based on the arm's length principle. The book, thus, examines the outer limits of …

sactions based on the arm’s length principle. This general rule is sometimes referred to as the “as-structured principle”. The first main issue examined in this thesis is the obligation under …