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Emerging Perspectives on the Evolving Arm’s Length Principle and Formulary Apportionment

Research output: Contribution to journal › Article › peer-review

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Emerging Perspectives on the Evolving Arm’s Length Principle and Formulary Apportionment. / Rogers, Helen; Oats, Lynne.
In: British Tax Review, Vol. 2019, No. 2, 17.05.2019, p. 150-165.

Research output: Contribution to journal › Article › peer-review

HarvardHarvard

Rogers, H & Oats, L 2019, 'Emerging Perspectives on the Evolving Arm’s Length Principle and Formulary Apportionment', British Tax Review, vol. 2019, no. 2, pp. 150-165.

APA

Rogers, H., & Oats, L. (2019). Emerging Perspectives on the Evolving Arm’s Length Principle and Formulary Apportionment. British Tax Review, 2019(2), 150-165.

CBE

Rogers H, Oats L. 2019. Emerging Perspectives on the Evolving Arm’s Length Principle and Formulary Apportionment. British Tax Review. 2019(2):150-165.

MLA

Rogers, Helen and Lynne Oats. "Emerging Perspectives on the Evolving Arm’s Length Principle and Formulary Apportionment". British Tax Review. 2019, 2019(2). 150-165.

VancouverVancouver

Rogers H, Oats L. Emerging Perspectives on the Evolving Arm’s Length Principle and Formulary Apportionment. British Tax Review. 2019 May 17;2019(2):150-165.

Author

Rogers, Helen ; Oats, Lynne. / Emerging Perspectives on the Evolving Arm’s Length Principle and Formulary Apportionment. In: British Tax Review. 2019 ; Vol. 2019, No. 2. pp. 150-165.

RIS

TY - JOUR

T1 - Emerging Perspectives on the Evolving Arm’s Length Principle and Formulary Apportionment

AU - Rogers, Helen

AU - Oats, Lynne

N1 - This is a pre-copyedited, author-produced version of an article accepted for publication in [insert journal title] following peer review. The definitive published version [Oats, L.M. and Rogers, H., 2019. Emerging Perspectives on the Evolving Arm’s Length Principle and Formulary Apportionment. B.T.R. 2019, 2, 150-165] is available online on Westlaw UK or from Thomson Reuters DocDel service .

PY - 2019/5/17

Y1 - 2019/5/17

N2 - A decade ago, the arm’s length principle on which transfer pricing rules and practices are based, was entrenched, and suggestions for change minimal and largely dismissed by practitioners. In this article we discuss more recent calls for a change in approach, many of which focus on some, form of formulary apportionment. While there is an increasing body of academic literature on formulary apportionment, it is much less referred to in the practitioner literature and has received less focus on the context of tax practitioners. We present evidence from a longitudinal study, of a change in attitude among senior transfer pricing professionals, from strong support for arm’s length pricing coupled with a dismissal of formulary apportioned, towards greater willingness to raise the limitations of arm’s length pricing.

AB - A decade ago, the arm’s length principle on which transfer pricing rules and practices are based, was entrenched, and suggestions for change minimal and largely dismissed by practitioners. In this article we discuss more recent calls for a change in approach, many of which focus on some, form of formulary apportionment. While there is an increasing body of academic literature on formulary apportionment, it is much less referred to in the practitioner literature and has received less focus on the context of tax practitioners. We present evidence from a longitudinal study, of a change in attitude among senior transfer pricing professionals, from strong support for arm’s length pricing coupled with a dismissal of formulary apportioned, towards greater willingness to raise the limitations of arm’s length pricing.

M3 - Article

VL - 2019

SP - 150

EP - 165

JO - British Tax Review

JF - British Tax Review

IS - 2

ER -