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Bridging the CCCTB and the Arm’s Length Principle – A Value Chain Analysis Approach

Updated: Oct 9, 2023

By René Offermanns, Steef Huibregtse, Louan Verdoner and Jakub Michalak.


This article provides an analysis of the proposals for a common consolidated tax base (CCTB) and common consolidated corporate tax base (CCCTB) in the European Union in the context of transfer pricing, concluding that a value chain analysis approach is the only possible means of aligning the CCCTB rules with the arm’s length principle.


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