Application of arm's length principle to intra-company dealings : back to the origins

Journal
Russo, R. (Raffaele)
International Transfer Pricing Journal 2005 (Volume 12), No. 1
PriceUSD 45

Examines the 2004 Discussion Draft on the attribution of profits to a permanent establishment. The author goes back to the origins of the arm's length principle, gives a comparison between the 2004 Draft and the OECD Commentary to Article 7 of the OECD Model, and presents some of his own observations on future topics and issues that are or may become relevant in this area.