Principio de plena competencia : ¿Afecta a los fines extrafiscales del Impuesto a la Renta?.

Abstract

The arm’s length principle consists that the terms and conditions in commercial transactions between related parties must be the same as a transaction celebrated between independent parties. The present work studies whether if the arm’s length principle affects the income tax extra purposes. Then, it is provided a brief analysis of the Arm’s Length Principle, Transfer Pricing, and Transfer Pricing Methods and relation between Arm’s Length Principle and the Income Tax. Apparently, the statement of this regime is complete, but it may affect the growth of international trade and investment if arm’s length principle is not applied in accordance with the guidelines of the Organization for Economic Co-operation and Development.