Arm’s-length standard has a future
September 15, 2010
The debate on the future of the arm’s-length standard (ALS), at International Tax Review's Global Transfer Pricing Forum in Amsterdam today, concluded that, while interesting arguments exist for an alternative method, the ALS is the only viable option because of its close connection to what happens in the market.
Dick Boykin, principal economist with Baker & McKenzie in the US, said he was unable to take formulary apportionment, the alternative to ALS that is most often referred to, seriously because of the problems there would be with implementing it.
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