The TP Bylaws set out approved transfer pricing methods to determine an arm's length
result which are based on the OECD TP Guidelines.
The term "not at arm's length
" means persons acting in concert without separate interests or who are related.
There are more than 130 major arm's length
companies delivering public services.
In some situations, relatives can be considered to be at arm's length
if the circumstances of their employment are substantially similar to those that would exist if they were dealing at arm's length
TEI further recommends that any more expansive ex post approach approved in the Guidelines be used only in conjunction with safe harbour rules, and that taxpayers be permitted to select either the safe harbour or the standard arm's length
* We overcome these conceptual and methodological deficiencies by examining how cultural distance influences aggregate arm's length
exports, while simultaneously considering its impact on aggregate arm's length
1.482-1 expressly requires that "the standard to be applied in every case is that of a taxpayer dealing at arm's length
with an uncontrolled taxpayer." (12) The court concluded that there could be no exceptions within the arm's-length context whereby a transaction could override what would occur between independent parties and still remain arm's length
However, all three of them have a common disadvantage which occurs when there's the lack of arm's length
Hold it at arm's length
while an adult lights it for you.
standard." This standard requires MNEs to
It makes little sense to try keeping them at arm's length
. If the parties develop a partnership that meets IRS guidelines, employment status becomes largely irrelevant and the parties can decide between the options based on legal and operational convenience.
Framing themselves at arm's length
, teenagers snap their own pictures and pass the camera to friends at school, e-mail the images, or upload them to the Internet.
AT ARMS LENGTH: Rangers Shota Arveladze keeps Derek Adams of Aberdeen at arm's length
at Pittodrie last night
There was no harsh regimentation--no ramrod straight spines and textbooks held at arm's length
at exactly the proper angle, as in the old films and photographs.
If, as you also say, COLF is an "arm of the CCCB," it is only in the sense that the CCCB is almost an arm's length
away from the hand that wrote the statement.