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TP or not TP: Examining the applicability of the arm's length principle to inter-company equity financing transactions

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Abstract

In this article, the authors examine the dynamics of inter-company equity financing transactions and conclude that the arm’ s length principle should be applied to such transactions even if they do not result in immediate profits or losses.
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Details

Original languageEnglish
Pages (from-to)497-505
Number of pages9
JournalBulletin for International Taxation
Volume67
Issue number9
Publication statusPublished - 1 Jan 2013