13 September 2018

International Monetary Fund and World Bank launch a new program offering their potential alternative to the arm’s-length principle

On 22 April 2018, the International Monetary Fund (IMF) and World Bank Group (WB) held a joint international tax conference as part of the WB’s Annual Spring Meetings entitled “Splitting the Riches: The Present and Future of Taxation by Formula.” The half-day session effectively marked the public launch of a new international tax research and work program that challenges the “conventional wisdom” of the arm’s-length principle (ALP) as the basis for deciding the division of taxing rights in relation to related-party transactions. The main aim of the program is to offer an alternative to ALP-based tax systems, designed to simplify assignment of taxing rights (especially for developing countries) and to create what these groups feel is a more equitable split of the tax base. An EY article provides details.

Document ID: 2018-6079