Tax planning disclosure and the arm’s length principle

In her recent blog on the Commission’s proposal on transparency rules for intermediaries, Paulina Szotek raises the interesting question whether this proposal embodies a separate EU concept of the arm’s length principle, distinct from that in the OECD’s transfer pricing guidelines. The question arises in the context of the following specific hallmark of potentially aggressive tax planning: ‘An arrangement or series of arrangements which does not conform with the arm's length principle or with the OECD transfer pricing guidelines, including the allocation of profit between different members of the same corporate group’ (Category E in the Annex to the draft Directive). Referring to the Commis

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