Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
CHAPTER 3
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COMPUTATION OF GloBE INCOME OR LOSS
PART 3-2
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ADJUSTMENTS TO DETERMINE GloBE INCOME OR LOSS
Division 2
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Other Article 3.2 adjustments
SECTION 3-105
3-105
MEANING OF ARM
'
S LENGTH PRINCIPLE
The Arm ' s Length Principle is the principle under which transactions between Constituent Entities of the same MNE Group must be recorded by reference to the conditions that would have been obtained between independent enterprises in comparable transactions and under comparable circumstances.
The Arm ' s Length Principle is the principle under which transactions between Constituent Entities of the same MNE Group must be recorded by reference to the conditions that would have been obtained between independent enterprises in comparable transactions and under comparable circumstances.
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