Home / 
Domestic Arm's Length Principle in Transfer Pricing Goes Beyond Tax Treaty Rules, Governing General Enterprise Taxation.
X X X X Extracts X X X X
X X X X Extracts X X X X
....ALP adjustments - there is a school of thought that a domestic arm’s length principle, which is what transfer pricing legislation represents, goes much beyond a tax treaty’s normal rule making scope since this arm’s length principle governs taxation of an enterprise in general and the tax treaties do not restrict domestic law in this respect - AT....