
doi: 10.59403/2nn5q53
Traditionally, the arm’s length principle relies on three pillars: the separate entity principle, the relevance of contractual arrangements and the comparability of the transaction. The purpose of this article is to show that, with the BEPS program and Pillars One and Two, new pillars have emerged in the form of allocation keys and safe harbours.
| selected citations These citations are derived from selected sources. This is an alternative to the "Influence" indicator, which also reflects the overall/total impact of an article in the research community at large, based on the underlying citation network (diachronically). | 2 | |
| popularity This indicator reflects the "current" impact/attention (the "hype") of an article in the research community at large, based on the underlying citation network. | Average | |
| influence This indicator reflects the overall/total impact of an article in the research community at large, based on the underlying citation network (diachronically). | Average | |
| impulse This indicator reflects the initial momentum of an article directly after its publication, based on the underlying citation network. | Average |
