The arm’s length principle seems to be under attack: the European Commission is exploring the Common Consolidated Tax Base (CCCTB), certain practitioners—including NGOs—are advocating global apportionments approaches, and others believe that the Organisation for Economic Co-operation and Development has betrayed the arm’s length principle in its latest Action 8-10 BEPS deliverable. |
In a roundtable organized by IFA France, NERA expert Dr. Emmanuel Llinares discussed the future of the arm’s length principle and how, on the contrary, BEPS restored its strength, which may be, to paraphrase Churchill, “the worst form of standard, except for all the possible others.” The event was co-chaired with lawyer and arbitrator Philippe Thiria and Edouard Marcus, Deputy Head of the French Tax Administration’s International Relations Directorate.
Visit the IFA France website for further details.
