Beyond the Arm's Length Principle

The arm’s length principle and the concept of permanent establishment are the two pillars of international corporate tax. Drafted in 1920, they are now under the fire of acute criticism and they appear to have become obsolete: they are unable to face the challenges of a global and digital economy.

After a critical analysis of the main international tax systems, this book proposes two orientations for international corporate taxation. First, it should rely on the source principle rather than the residence principle. Second, it should embrace the Common consolidated corporate tax base proposed by the EU, rather than the Pillar One proposed by the OECD.