As has been shown, the problem underlying almost any
tax evasion problem associated with TNCs is that relationships
that normally occur between separate entities
from different owners occur between entities belonging
to the same owner. Therefore, the core solution to
this problem has thus far been to compare intra-firm
transactions with comparable transactions between
unrelated entities or enterprises – and then require the
Figure 2: SAB Miller‘s affiliates
Source: Hearson 2011.
SAB Miller
Management BV (NL)
SAB Miller
International VB (NL)
Bevman AG
(Switzerland)
MUBEX
(Mauritius)
Management fees
Royalties
Management fees
Procurement of goods
National
Breweries (ZA)
Zambian
Breweries
South African
Breweries
Accra Breweries
(Ghana)
Tanzanian
Breweries
Cervejas de
Mocambique
MARKUS HENN | TAX HAVENS AND THE TAXATION OF TRANSNATIONAL CORPORATIONS
8
intra-firm trade to be the same as the extra-firm one.
This approach became known as the »Arm’s Length
Principle« (ALP).