Battered and bruised but still standing

International Tax Review is part of Legal Benchmarking Limited, 4 Bouverie Street, London, EC4Y 8AX

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Cookies Settings

Battered and bruised but still standing

August 31 2009

The arm's length principle was included in the first OECD transfer pricing guidelines in 1979. Since then it has been subject to great debate. Catherine Snowdon looks at what could threaten the principle's future.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

FeatureUnited StatesCover storyIndiaTransfer PricingIrelandBrazilITR MagazineSeptember 2009Latin America and Caribbean
more across site & shared bottom lb ros

More from across our site

Direct Tax
OECD building
OECD countries ‘more reliant on’ corporate income tax revenue
Despite a general decline in corporate tax rates around the world, jurisdictions are now more reliant on it than in 1990, a Tax Foundation economist found
Sam Sholli, May 23 2025
Direct Tax
PwC.jfif
This week in tax: PwC Australia has met most governance targets, post-scandal report says
Australian law firm Webb Henderson’s report said PwC had met 46 of 47 targets; in other news, the OECD has issued new transfer pricing country profiles
Sam Sholli, May 23 2025
Transfer Pricing
Munich
WTS Germany acquires Baker McKenzie tax team in post-investment play
The arrival of a seven-strong team from Baker McKenzie will boost WTS Germany’s transfer pricing capabilities and help it become ‘a European champion’, the firm’s CEO said
Tom Baker, May 21 2025
Indirect Tax
beckmann al hkim.jpg
‘Right step, executing wrongly’: Local expert dissects Germany’s e-invoicing implementation
Germany has forgotten to think about digital reporting requirements, a WTS partner claimed at ITR’s Indirect Tax Forum 2025
Sam Sholli, May 21 2025
Indirect Tax
e-invoicing
The evolution of interoperability in e-invoicing
E-invoicing is currently characterised by dynamism, with fragmentation acting as a key catalyst for increasing interoperability, says Aida Cavalera of the International Observatory on eInvoicing
Aida Cavalera, May 20 2025
Direct Tax
scott levine resized.jpg
US pillar two deal still alive, ex-Treasury deputy says
Pillar two and the US tax system ‘could work in harmony’, Scott Levine tells ITR in an exclusive interview to mark his arrival at Baker McKenzie
Tom Baker, May 19 2025
Direct Tax
Businessman putting a card with text code of ethics in the pocket
‘Serious, deliberate, dishonest’: Ex-EY Australia partner banned over misconduct
Peter White, who has a tax debt of A$2 million, has been banned for five years from seeking registration with Australia’s Tax Practitioners Board (TPB)
Sam Sholli, May 16 2025
Direct Tax
wopke hoekstra.jpg
This week in tax: Pillar two deal won’t disadvantage EU companies, tax chief says
Wopke Hoekstra’s comments followed US measures aimed against ‘unfair foreign taxes’; in other news, Grant Thornton and Holland & Knight made key tax partner hires
Sam Sholli, May 16 2025
Transfer Pricing
Mining
Key evidentiary lessons for taxpayers: experts dissect Australia TP case
An Administrative Review Tribunal ruling last month in Australia v Alcoa represents a 'concerning trend' for the tax authority, one expert tells ITR
Sam Sholli, May 15 2025
Direct Tax
Round trip, flight, globe
Indian High Court upholds ‘round tripping’ reassessment: expert analysis
A recent decision underlines that Indian courts are more willing to look beyond just legal compliance and examine whether foreign investment structures have real business substance
Sanjay Sanghvi, May 14 2025
Gift this article