An arm's length transaction, also known as the arm's length principle (ALP), indicatesa transaction between two independent parties in which both parties are acting in their own self-interest. Both buyer and seller are independent, possess equal bargaining power, are not under pressure or dures...
. . . Everything in the construction of Section 2 must be regarded as directed toward the collection of the taxes imposed and Section 1 of the prevention of evasion by persons subject to the tax.56 Criminal penalties were imposed to secure evidence of the transaction in order that it may ...
In relation to the assessment of "arm's length value": Justice Logan undertook a forensic analysis of the text of the section 21A to assess the statutory context and assessed that it should not be determined by reference to the transaction between the parties in respect of the be...