arm's length

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a distance sufficient to exclude intimacy

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References in periodicals archive ?
Such re-pricing, however, would not be undertaken by unrelated parties and constitutes a significant deviation from the arm's length principle.
Taxpayer and tax administrator experience with the imprecise process for determining an arm's length price suggests that there is room within the arm's length principle for administrative tolerance for all taxpayers--large MNCs as well as smaller taxpayers.
The arm's length principle does not require compensation for a mere decrease in the expectation of an entity's future profits.
Where the taxpayer provides the necessary data and documentation to establish that its prices are more likely than not arm's length, the taxpayer should be accorded a rebuttable presumption that its prices satisfy the arm's length principle with the burden of proving otherwise shifting to the tax administration," the comments said.
10 confirms that the arm's length principle does not require the application of more than one method for a given transaction (or set of transactions) and "undue reliance on such an approach could create a significant burden for taxpayers.
The TP Guidelines were developed to ensure the arm's length principle is observed in transactions between related parties.
Transfer pricing rules are aimed at protecting Canada's tax base by encouraging taxpayers to adhere to the arm's length principle.
to establish transfer prices in accordance with the arm's length principle.
TEI commends the OECD for its work on the application of the arm's length principle to cross-border commodity transactions in the Discussion Draft.
Keywords: transfer pricing, tax avoidance, intangibles, arm's length principle, profit allocation
Namibia introduced transfer pricing legislation in 2005, aimed at enforcing the internationally accepted arm's length principle in cross-border transactions carried out between connected persons.
This aim could be achieved by setting aside domestic rules and using the new Article 7 of the OECD Model Convention as a paradigm to establish an international consensus for the capital structure of both permanent establishments and subsidiaries in line with the arm's length principle.
Transfer pricing and the arm's length principle in international tax law.
In a multilateral context the arm's length principle was formulated for the first time in Article 6 of the League of Nations draft Convention on the Allocation of Profits and Property of International Enterprises in 1936.
But implementing the arm's length principle is easier said than done.