Resolving Transfer Pricing Disputes: A Global Analysis

doi:10.1017/CBO9781139208123

Resolving Transfer Pricing Disputes

A Global Analysis

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Cited by 8
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Baistrocchi, Eduardo 2012. Tax Disputes under Institutional Instability: Theory and Implications. The Modern Law Review, Vol. 75, Issue. 4, p. 547.

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Pichhadze, A. 2013. Canada’s Transfer Pricing Test in the Aftermath of GlaxoSmithKline Inc.: A Critique of the Reasonable Business Person Test. International Transfer Pricing Journal, Vol. 20, Issue. 3,

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Wang, J.(Jingyi) 2013. Business Restructurings: A Case Analysis and Regulations Applicable to Business Restructurings. International Transfer Pricing Journal, Vol. 20, Issue. 5,

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Pichhadze, Amir 2015. Exposing Unaddressed Issues in the OECD’s BEPS Project: What About the Roles and Implications of Contract Interpretation Law and Private International Law in the Transfer Pricing Arm’s Length Comparability Analysis?. World Tax Journal, Vol. 7, Issue. 1,

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Escobar, Ricardo and Muñoz, Mirenchu 2017. A Global Analysis of Tax Treaty Disputes. p. 172.

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Nicolay, Katharina Nusser, Hannah and Pfeiffer, Olena 2017. On the Interdependency of Profit Shifting Channels and the Effectiveness of Anti-Avoidance Legislation. SSRN Electronic Journal ,

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Eden, S.(Sandra) 2017. Tax Avoidance Revisited in the EU BEPS Context. Vol. 15, Issue. ,

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Quoc Thinh, Tran and Thi Hai An, Nguyen 2023. The influence of income tax rate, tunneling incentives, and return on equity on transfer pricing behavior of foreign direct investment enterprises in Vietnam. Investment Management and Financial Innovations, Vol. 20, Issue. 4, p. 194.

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Edited by Eduardo Baistrocchi, London School of Economics and Political Science, Ian Roxan, London School of Economics and Political Science

Publisher:: Cambridge University Press
Online publication date:: November 2014
Print publication year:: 2012
Online ISBN:: 9781139208123
DOI:: https://doi.org/10.1017/CBO9781139208123

Subjects:: Economics, Law, Finance and Accountancy, Taxation Law
Series:: Cambridge Tax Law Series

377.00 (USD)

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Via a global analysis of more than 180 transfer pricing cases from 20 representative jurisdictions, Resolving Transfer Pricing Disputes explains how the law on transfer pricing operates in practice and examines how disputes between taxpayers and tax administrations are dealt with around the world. It has been designed to be an essential complement to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, which focus on transfer pricing issues but do not refer to specific transfer pricing disputes. All of the transfer pricing cases discussed in the book are linked to the relevant paragraphs of the OECD Guidelines by means of a 'Golden Bridge', namely a table listing the cases according to the paragraphs of the Guidelines to which they refer. It therefore provides examples of the application of the Arm's Length Principle in many settings on all continents.

'… this work is an extremely useful contribution to an important field of study. The focus on historical and cultural contexts combined with the 'nuts and bolts' detail of resolving disputes, along with the fact that such a large number of jurisdictions are canvassed, makes this an especially unique and attractive title.'

Glen Loutzenhiser Source: British Tax Review

'… the work's contribution to the international tax literature is ensured.'

Diane M. Ring Source: Tax Notes International

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Resolving Transfer Pricing Disputes

A Global Analysis

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