There's one big, recurring criticism of the arm's length principle in #transferpricing that I think needs to be "re-accommodated": ...
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Replying to @phdskat
That multinational groups are assumed to be independent entities. They are not. That's how the application of TP rules treats them, but ...
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Replying to @phdskat
TP peeps, academics & practitioners know it's not true. The assumption is that it's best way to achieve fair outcome, not that it's reality
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Replying to @phdskat
Now, that can certainly be discussed. And should be. On the correct basis, rather than functional straw men.
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Replying to @phdskat
Surely the criticism is that ALP is based on assumption that intragroup trade *should* be priced that way?
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Replying to @alexcobham @phdskat
So the criticism is not that ALP assumes factual falsehood of independence, but factual falsehood that independent pricing=> 'right' outcome
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Do you mean like this articulation by @_DavidQuentin ?https://www.degruyter.com/view/j/ael.ahead-of-print/ael-2016-0020/ael-2016-0020.xml?format=INT … (or what is a good example of the right criticism?)
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