Arm"s length transaction structures
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Arm"s length transaction structures recognizing and restructuring controlled transactions in transfer pricing by Andreas Bullen

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Published by IBFD, Academic Council in Amsterdam .
Written in English


  • Corporations,
  • Taxation,
  • Transfer pricing,
  • Law and legislation

Book details:

Edition Notes

StatementAndreas Bullen
SeriesDoctoral series -- v. 20, Doctoral series -- v. 20.
LC ClassificationsK4550 .B85 2011
The Physical Object
Paginationxlvi, 878 p. ;
Number of Pages878
ID Numbers
Open LibraryOL25211495M
ISBN 10908722088X
ISBN 109789087220884
LC Control Number2011291695

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transaction structuresadopted by associated enterprises is perhaps less understandable. The thesis “Arm’s length transaction structures: Recognising and restructuring controlled transactions in transfer pricing”, addresses two primary issues, as its subtitle indicates. The intuitive step-by-step guidance, together with integrated Excel-based tools, will equip the reader to ensure compliance with the arm’s length principle and thus to minimize tax risk. Based on the post-BEPS OECD Guidelines, the book’s content is applicable to a global : Springer International Publishing. CERTIFICATION OF ARMS-LENGTH TRANSACTION The undersigned, being all of parties or the representatives of the parties to that certain Agreement dated _____,_____(the “Agreement”) for the sale of that certain real property commonly known as _____(the “Property”), hereby certify under penalty of perjury under the laws of the State of. What is Arm’s Length Transaction? Arm’s length transaction means a transaction between two enterprises, such that the parties act independently, and the price agreed between them (also known as transfer price) is free from any influence that maybe they’re due to the relation between parties who are not independent.

arm's length transaction: translation Said of a transaction negotiated by unrelated parties, each acting in his or her own self interest; the basis for a fair market value determination. A transaction in good faith in the ordinary course of business by parties with independent interests.   An arm's length transaction refers to a business deal in which buyers and sellers act independently without one party influencing the other.   An arm's length transaction is one in which both parties are acting in their own best interest. That means they have negotiated fairly on price, and neither party is giving the other one a deal better or worse than the market would dictate because of an existing relationship between them.   In real estate, an arm's length transaction is when the buyer and seller each act in their own self-interest to try to get the best deal they can. In most sales, a seller is trying to make a large.

  The first is that the borrowing entity could and would potentially get access to a similar level of debt, with similar terms and conditions, from a third-party lender. The second is that the interest rate is priced in accordance with arm’s length transactions in which comparable, unrelated parties would enter into similar agreements. An arms-length transaction is one in which the property was exposed for sale in the open market, and the transaction involved a willing seller and a willing buyer, both of whom are knowledgeable concerning all the uses to which it is adapted and for which it is capable of being used. Improved property is land with one or more structures on it. Chapter 1 Introduction Transaction structures and the arm’s length principle Both associated and unrelated enterprises negotiating a contract will fre- quently face numerous ways of structuring their contractual relationship. To be sure, certain aspects of the contract structure are predetermined. This can have major tax or legal ramifications in the future. In fact, mortgage loan fraud lawsuits often appear in the news when an arm’s length transaction was not conducted. In order to operate safely and by-the-book, an arm’s length transaction must be performed. An .