Arm's length principle from a Swiss perspective profit allocation to inbound and outbound permanent establishments Céline Martin, Vikram Chand & Natassia Burkhalter
By: Martin, Céline
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Contributor(s): Chand, Vikram | Burkhalter Martínez, Natassia.
Material type: 
ArticlePublisher: 2022Subject(s): ESTABLECIMIENTO PERMANENTE | IMPUESTOS | PRINCIPIO DE PLENA COMPETENCIA | SUIZA
In:
Intertax v. 50, issue 1, January 2022, p. 66-81Summary: The article discusses the application of the arm's length principle from a Swiss tax treaty and Swiss national law perspective as applicable to transactions among separate entities as well as to head office and permanent establishment (PE) relations. It provides an overview of the profit allocation rules applicable in domestic and international cases. Moreover, for illustration, two case studies are developed and analysed for cross-border relations with fixed place PEs (inbound and outbound cases) and an example is provided for the interaction between international and domestic profit allocation.
| Item type | Current location | Home library | Call number | Status | Date due | Barcode |
|---|---|---|---|---|---|---|
| Artículos | IEF | IEF | OP 2141/2022/1-6 (Browse shelf) | Available | OP 2141/2022/1-6 |
Resumen.
The article discusses the application of the arm's length principle from a Swiss tax treaty and Swiss national law perspective as applicable to transactions among separate entities as well as to head office and permanent establishment (PE) relations. It provides an overview of the profit allocation rules applicable in domestic and international cases. Moreover, for illustration, two case studies are developed and analysed for cross-border relations with fixed place PEs (inbound and outbound cases) and an example is provided for the interaction between international and domestic profit allocation.
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