Rules on Intangible Sales – The Real Problem with the Arm’s Length Principle

Journal
Musselli, A.
International; OECD
Bulletin for International Taxation 2024 (Volume 78), No. 5
Price USD 45

Profit shifting appears to be driven by underpriced group intangible sales to low-taxed affiliates derived from valuations resulting from income allocation methods. The enforcement of the periodic adjustment of the intangible price cannot definitively avoid this problem, but could (partly) avoid sales in breach of the arm’s length principle.