TPG2017 Chapter IV paragraph 4.110

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The availability of safe harbours for a given category of taxpayers or transactions may have adverse consequences. These concerns stem from the fact that:

  1. The implementation of a safe harbour in a given country may lead to taxable income being reported that is not in accordance with the arm’s length principle;
  2. Safe harbours may increase the risk of double taxation or double non-taxation when adopted unilaterally;
  3. Safe harbours potentially open avenues for inappropriate tax planning, and
  4. Safe harbours may raise issues of equity and uniformity.





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