The arm’s length principle and equity dispositions electrónico the case of thick capitalization : part 1 Andreas Bullen and Morten Goller
By: Bullen, Andreas
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Contributor(s): Goller, Morten.
Material type: 
ArticleSubject(s): PRECIOS DE TRANSFERENCIA | PRINCIPIO DE PLENA COMPETENCIA | CAPITAL | OPERACIONES FINANCIERAS | ACCIONES | NORUEGA | ORGANIZACION DE COOPERACION Y DESARROLLO ECONOMICO
In:
International Transfer Pricing Journal v. 29, n. 2, 2022, p. 126-134Summary: The arm’s length principle has existed for more than 100 years, and a large number of equity dispositions have been undertaken for even more years. Still, neither the OECD nor the Norwegian legislator has ever suggested that the arm’s length principle can be applied to equity dispositions. Is this a coincidence or are there valid reasons for not applying the arm’s length principle to equity dispositions? In this article, the authors examine this issue from the perspective of the arm’s length provision contained in the OECD Model and Norwegian domestic law, aimed at the particular case of thick (equity) capitalization.
| Item type | Current location | Home library | Call number | Status | Date due | Barcode |
|---|---|---|---|---|---|---|
| Recursos electrónicos | IEF | IEF | ITPJ/2022/2-10 (Browse shelf) | Available | ITPJ/2022/2-10 |
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Resumen.
The arm’s length principle has existed for more than 100 years, and a large number of equity dispositions have been undertaken for even more years. Still, neither the OECD nor the Norwegian legislator has ever suggested that the arm’s length principle can be applied to equity dispositions. Is this a coincidence or are there valid reasons for not applying the arm’s length principle to equity dispositions? In this article, the authors examine this issue from the perspective of the arm’s length provision contained in the OECD Model and Norwegian domestic law, aimed at the particular case of thick (equity) capitalization.
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