In view of the current widespread acceptance and usage of the &quot; arm &apos; s length standard &quot; (or &quot; arm &apos; s length principle &quot; ALP), included in the UN Model Tax Convention (UN MTC), and the benefit, in avoiding double taxation, of common approaches across countries, this Manual addresses currently accepted approaches of applying this standard in a developing country context.
In view of the current widespread acceptance and usage of the &quot; arm &apos; s length standard &quot; (or &quot; arm &apos; s length principle &quot; ALP), included in the UN Model Tax Convention (UN MTC), and the benefit, in avoiding double taxation, of common approaches across countries, this Manual addresses currently accepted approaches of applying this standard in a developing country context.