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  1. 1. Can the Arm’s Length Principle in the OECD Transfer Pricing Guidelines Fulfil the Minimum Requirements of the Transaction Approach in the Controlled Foreign Company Rules under Anti-Tax Avoidance Directive?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Zhijie Qiu; [2019]
    Keywords : Arm s Length Principle; CFC Rules; ATAD; BEPS; Law and Political Science;

    Abstract : Generally, the ALP in TP regulations is widely applied in order to prevent price manipulation which will cause tax avoidance. And CFC regulations have usually been regarded as a “backstop” of TP regulations in terms of combating tax avoidance. READ MORE