Following, you will find the document prepared by our senior associate, Gert Greve, for the Journal of Tax Studies of the Faculty of Economics and Business of the Universidad de Chile. He explains three reasons why he declares that the arm’s length principle does not reflect the economic reality of the modern multinational company.
He argues that “technology now allows multinational companies to access foreign markets with minimal physical presence. In this sense, the digitization of the economy is challenging the roots of the past political consensus. From the foregoing, the claim of certain jurisdictions to “rebalance” tax rights in the international community arises”, but that this is not possible.
To read the document, here.