The Arm's Length Principle, Tax Treaties, and the Multilateral Instrument 2021 | American Bar Association (ABA) | 15 September 2021 | Online Event

Will Pillar One’s new taxing right diminish the iconic status of the arm's length standard, and if so, with what long-term impact on tax treaties? What are the implications of Pillar One’s reliance on formulary apportionment as a mechanism for taxing the digital economy? Are multilateral instruments an appropriate and effective tool for administering the realignment of taxing rights under Pillars One and Two? In the September installment of our webinar series, Professor Avi-Yonah assesses whether the arm's length standard is still fit for purpose in the digital age.