Rethinking Profit Attribution: Exploring Models Derived from the Arm’s Length Principle and Beyond

While debates continue under Workstream II of the UN Framework Convention on International Tax Cooperation and the UN Committee of Tax Experts, developing countries, face both capacity and conceptual gaps in identifying feasible and preferably harmonized alternatives to the ALP. This article is a working paper that aims to fill the knowledge gap by providing a structured overview and comparative assessment of profit attribution models. It reviews existing and emerging approaches, assessing their theoretical underpinnings, practical feasibility and implications for administrative capacity, equity and simplicity. The article provides high-level evaluations listing possible advantages or shortcomings of the respective models but expressly does not advocate any particular model.

Authors

Publication Details

Journal
International Transfer Pricing Journal
Published
2026-03-26
DOI
https://doi.org/10.59403/27mt5ky
Primary Topic
Corporate Taxation and Avoidance
Type
article
Field-Weighted Citation Impact
0.00
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article

Rethinking Profit Attribution: Exploring Models Derived from the Arm’s Length Principle and Beyond

Aisha Aize Isa
International Transfer Pricing Journal
Corporate Taxation and Avoidance
article

Rethinking Profit Attribution: Exploring Models Derived from the Arm’s Length Principle and Beyond

Aisha Aize Isa
article en

Abstract

While debates continue under Workstream II of the UN Framework Convention on International Tax Cooperation and the UN Committee of Tax Experts, developing countries, face both capacity and conceptual gaps in identifying feasible and preferably harmonized alternatives to the ALP. This article is a working paper that aims to fill the knowledge gap by providing a structured overview and comparative assessment of profit attribution models. It reviews existing and emerging approaches, assessing their theoretical underpinnings, practical feasibility and implications for administrative capacity, equity and simplicity. The article provides high-level evaluations listing possible advantages or shortcomings of the respective models but expressly does not advocate any particular model.

International Transfer Pricing JournalVol. 33(3)
Partnerships for the goals
Openalex Percentile: Top 8%
Corporate Taxation and Avoidance
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