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An arm's length relationship is distinguished from a fiduciary relationship, where the parties are not on an equal footing, but rather, power and information asymmetries exist. It is also one of the key elements in international taxation as it allows an adequate allocation of profit taxation rights among countries that conclude double tax ...
A frequently-proposed [107] [108] alternative to arm's-length principle-based transfer pricing rules is formulary apportionment, under which corporate profits are allocated according to objective metrics of activity such as sales, employees, or fixed assets. Some countries (including Canada and the United States) allocate taxing rights among ...
[56] [57] If a joint venture is conducted at commercial arm's length and both parties are on an equal footing then the courts will be reluctant to find a fiduciary duty, but if the joint venture is carried out more in the manner of a partnership then fiduciary relationships can and often will arise. [58] [59] [56]
Non-arm’s length transactions. A non-arm’s length transaction is one in which the seller and buyer have a pre-existing relationship, whether it’s business-related or personal. This is ...
What does this ending mean for Elliot and his relationship with time travel? ... Elliot has always been someone who kept time travel at arm’s length. To make this realization, or create this ...
The relationship ignites tensions with her family when they suspect his intentions carry a hidden agenda. ... satisfy wealthy clients while keeping them at arm’s length. But when his boss, Minou ...
These two are in a regular contractual, arm's length, non-fiduciary, non-equity relationship. Rather, the trustee in a "trust indenture" is a third party, usually a specialist company, who is appointed by the issuer to handle and safeguard the interests of the numerous public bondholders, in events ranging from the usual distribution of coupons ...
In the United Kingdom, an arms-length management organisation (ALMO) is a not-for-profit company that provides housing services on behalf of a local authority. Usually, an ALMO is set up by the authority to manage and improve all or part of its housing stock. Ownership of the housing stock itself normally stays with the local authority.