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Is the Arm’s Length Principle still fit for purpose? electrónico Bo Wingerter

By: Wingerter, Bo.
Material type: ArticleArticlePublisher: 2021Subject(s): IMPUESTO DE SOCIEDADES | PRECIOS DE TRANSFERENCIA | PRINCIPIO DE PLENA COMPETENCIA | UNION EUROPEA In: International Transfer Pricing Journal v. 28, n. 5, 2021Summary: On 18 May 2021, the European Commission issued a press release announcing an ambitious new project: the creation of a business taxation framework that would be both suitable and sustainable for the 21st century. Embedded in this project was an outline of the Business in Europe: Framework for Income Taxation, or “BEFIT” proposal. In this article, the author examines the merits, as well as the potential downfalls, of the European Commission’s proposal, including an assessment of whether such a project is necessary given the ongoing initiatives at the level of the OECD.
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Resumen.

On 18 May 2021, the European Commission issued a press release announcing an ambitious new project: the creation of a business taxation framework that would be both suitable and sustainable for the 21st century. Embedded in this project was an outline of the Business in Europe: Framework for Income Taxation, or “BEFIT” proposal. In this article, the author examines the merits, as well as the potential downfalls, of the European Commission’s proposal, including an assessment of whether such a project is necessary given the ongoing initiatives at the level of the OECD.

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