Safe Harbors: Is the Arm’s Length Principle Losing Its Grip?
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Safe Harbors: Is the Arm’s Length Principle Losing Its Grip?
The arm’s length principle has been the foundation of transfer pricing rules for decades. It says that companies in the same group should price their cross-border transactions as if they were unrelated. However, global businesses today are more interconnected, data-driven, and centered around intangible assets. In this new world, ALP is becoming harder to apply and manage.
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