Today we live in a globalizing economy: national open markets are steadily developing towards a global market. Within the European Union, the internal market without internal frontiers has been established. However, the fiscal sovereignty of nation states remains limited to economic activities...

The OECD Base Erosion Profit Shifting (BEPS) Initiative as well as the current fairness oriented public discussion regarding the taxation of digital business models highlight the importance and complexity of the arm’s length principle. In a theoretical model of an internationally fragmented...