We use cookies on this site to provide you with an informative and engaging experience and also to help us to continually improve our site for you. Without allowing cookies certain features of the site will not be available. To learn more about how we use cookies, please view our cookie policy. By clicking on ‘I AGREE’, you consent to our use of cookies on this device in accordance with our policy.

Logo of Wolters Kluwer, Kluwer Law Online

Home > All journals > Intertax > 49(10) >

The Multilateral Instrument (MLI) and Transfer Pricing

Cover image ofIntertax

$25.00 - Rental (PDF) *

$49.00 - Article (PDF) *

*service fee may apply
The Multilateral Instrument (MLI) and Transfer Pricing


Intertax
Volume 49, Issue 10 (2021) pp. 803 – 817

https://doi.org/10.54648/taxi2021086



Abstract

The Multilateral Instrument (MLI) has a relevant impact on tax treaty measures concerning transfer pricing and the arm’s length principle (ALP). This article examines the incidence of five MLI provisions on transfer pricing that pose significantly interrelated issues, specifically, the saving clause of Article 11(1), the preamble enclosed in Article 6(1) expressing the will to eliminate double taxation without creating opportunities for reduced taxation through tax evasion or avoidance enshrined in the principal purpose test of Article 7(1), the corresponding adjustment provision of Article 17(1), and the mutual agreement provisions envisaged in Article 16.


Keywords

MLI, multilateral instrument, tax treaties, transfer pricing, arm’s length principle, abuse, corresponding adjustments, MAP.


Extract




Subscribe to this journal

Interested in a subscription? Contact our sales team

Contribute to this journal

Go Directly to PeerEase! Submit Article

Browse by practice area
Share
Stay up to date


RSSETOC