Perspectives and Future Prospects of the Arm's Length Principle at EU Level Considering the Proposed European Transfer Pricing Directive (Part One)

This two-part article examines the arm’s length principle from a European perspective. Part One analyses the implications resulting from the 2023 EU Directive on transfer pricing as well as its possible replacement by an EU TP Platform. Part Two, which will appear in the next issue of the Bulletin, provides critical commentary, connecting the EU initiative to broader international tax developments.