1. The IIR and the top-down approach
It has become commonplace that the current OECD and Inclusive Framework (IF) proposals to address the tax challenges of the digital economy will represent a…
Introduction
There is no divine truth about what the Arm’s Length Standard (ALS) actually means. Its content can only be determined by a decision, which can be reached by a court or by means of…
Brazil is known for its unique transfer pricing legislation. While in most countries the use of comparables is central for the application of the transfer pricing methods, the Brazilian system has…
As from the first BEPS proposals with respect to intangibles, it has been considered that the Arm’s Length Standard (“ALS”) is “slowly but surely being relegated to the back seat” of the OECD…
