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Melissa Ogier

Working paper

Mind the gap - The arm's length principle and MNE value creation


Multinational enterprises (MNEs) operating by way of wholly owned subsidiaries are responsible for an increasing percentage of global trade. This paper looks at how the existing rules based on the arm’s length principle allocate a MNE’s profit between the taxing jurisdictions in which it operates. It highlights the limitations of the arm’s length principle by...

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