Finality and Fairness in Tax Arbitration

Document Type

Article

Publication Date

1994

ISSN

2212-182X

Publisher

Kluwer Law International

Language

en-US

Abstract

To reduce international tax evasion, fiscal authorities sometimes adjust the taxable profits earned by multinational enterprises in connection with intra-group sales, services or loans. Amounts charged by one member of a corporate family to another might be increased or reduced, depending on the factual configuration of the case, to reflect the fair market values of comparable transactions concluded on an "arm's length" basis with unrelated parties.

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