The effective implementation of the arm’s-length principle is closely linked to the availability of information. In transfer pricing, the asymmetry of information between taxpayers and tax administrations can be acute, potentially opening opportunities for BEPS. For this reason, the BEPS Action Plan stressed the need to enhance transparency in general, and for transfer pricing purposes in particular. Andrew Hickman, Samia Abdelghani and Paul Hondius explain these enhancements in the context of Action 13.
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The BEPS project has seen the arm’s-length principle shift its focus to where human activity takes place, but Leonard Wagenaar questions if this is sustainable in a financialised world
Anticipating potential changes in tax basis interpretations can help reduce audit risks in tax planning for intercompany equity transfers, says Abe Zhao of FenXun partners