Research in Brief 46

The global consensus to treat multinational enterprises (MNEs) as separate entities for tax purposes requires them to act at arm’s length in the transfer of goods and services, especially setting the prices of such transfers. This means that, although in practice they are integrated entities under the ownership and control of a parent company, operating through a central management and vertical organisational structure, they must produce accounts in each country based on the fiction that they transact as independent entities would when transferring goods and services between associated enterprises. This arm’s length standard was established over eight decades ago and embodied in article 9 of the model tax treaties. It remains the global standard for the treatment of MNEs. This ICTD Research in Brief is a two-page summary of ICTD Working Paper 100 by Alexander Ezenagu.


Alexander Ezenagu

Dr Alexander Ezenagu is an Assistant Professor of Taxation and Commercial Law at Hamad Bin Khalifa University, Qatar and an ICTD Research Associate. He obtained his doctorate degree in International Tax Law at McGill University, Canada, and holds a Master of Law degree (LL.M) from the University of Cambridge, United Kingdom. As a researcher, Alexander focuses on international tax law and policy issues, with emphasis on the relationship between taxation and economic development and on the role of government and non-government institutions and actors in the creation of tax policy norms.
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