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Resolving Transfer Pricing Disputes
A Global Analysis


Part of Cambridge Tax Law Series

Ian Roxan, Eduardo Baistrocchi, Reuven S. Avi-Yonah, David G. Duff, Byron Beswick, Philip Gillett, Andreas Oestreicher, Violeta Ruiz Almendral, Richard Vann, Toshio Miyatake, Hun Park, Stephen Phua Lye Huat, Isabel Calich, Joao Dacio Rolim, Andrey Shpak, Mukesh Butani, Jinyan Li, Juan Pablo Guerrero Daw, Ofer Granot, Yoram Margalioth, Lee Corrick
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  • Date Published: December 2012
  • availability: Available
  • format: Hardback
  • isbn: 9781107026599
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About the Authors
  • 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.

    • Links transfer pricing cases from around the world to the OECD Guidelines
    • Compares countries with long-established transfer pricing systems, such as Germany, Japan, the United Kingdom and the United States, to those with newer versions, such as Brazil, Russia, India and China
    • Provides details of transfer pricing in twenty countries, using a representative selection of jurisdictions in transfer pricing on all continents
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    Reviews & endorsements

    '… 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, British Tax Review

    '… the work's contribution to the international tax literature is ensured.' Diane M. Ring, Tax Notes International

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    Customer reviews

    22nd May 2014 by DannyBeeton

    A unique and hugely valuable illumination of how the international transfer pricing guidance can be interpreted and applied by reference to the methods considered and approved in key tax cases from around the world. The book is also a guide to the transfer pricing dispute resolution process in many key jurisdictions, and explains how the interpretation of the Arms Length Principle is itself evolving.

    23rd Jul 2015 by GianniDeRobertis

    A unique and valuable contribution to the field of transfer pricing, which provides a picture of the practical application of the arms length principle in various contries. The book is a very good reference guide, easy to use, as it contains a link between the content of the transfer pricing disputes covered in the text and the relevant sections of the OECD Guidelines the Golden Bridge. It would be good to add further countries in future editions e.g. Italy and France.

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    Product details

    • Date Published: December 2012
    • format: Hardback
    • isbn: 9781107026599
    • length: 990 pages
    • dimensions: 229 x 152 x 51 mm
    • weight: 1.48kg
    • contains: 23 b/w illus. 34 tables
    • availability: Available
  • Table of Contents

    1. Introduction Ian Roxan
    2. The transfer pricing problem Eduardo Baistrocchi
    Part I. North America and Europe:
    3. Transfer pricing disputes in the United States of America Reuven S. Avi-Yonah
    4. Transfer pricing disputes in Canada David G. Duff and Byron Beswick
    5. Transfer pricing disputes in the European Union Philip Gillett
    6. Transfer pricing in Germany Andreas Oestreicher
    7. Transfer pricing in Spain Violeta Ruiz Almendral
    8. Transfer pricing disputes in the United Kingdom Ian Roxan
    Part II. Asia-Pacific:
    9. Transfer pricing disputes in Australia Richard Vann
    10. Transfer pricing disputes in Japan Toshio Miyatake
    11. Transfer pricing disputes in the Republic of Korea Hun Park
    12. Transfer pricing in Singapore Stephen Phua Lye Huat
    Part III. BRIC Countries:
    13. Transfer pricing disputes in Brazil Isabel Calich and Joao Dacio Rolim
    14. Transfer pricing disputes in the Russian Federation Andrey Shpak
    15. Transfer pricing disputes in India Mukesh Butani
    16. Transfer pricing disputes in China Jinyan Li
    Part IV. South America, Middle East and Africa:
    17. Transfer pricing disputes in Argentina Eduardo Baistrocchi
    18. Transfer pricing disputes in Chile Juan Pablo Guerrero Daw
    19. Transfer pricing disputes in Israel Ofer Granot and Yoram Margalioth
    20. Transfer pricing disputes in Africa Lee Corrick
    21. Transfer pricing dispute resolution: the global evolutionary path (1799–2011) Eduardo Baistrocchi
    22. Resolving transfer pricing disputes: an analysis of the globe Ian Roxan.

  • Editors

    Eduardo Baistrocchi, London School of Economics and Political Science
    Eduardo Baistrocchi is an Associate Professor of Law at the London School of Economics and Political Science, having joined in 2009. Before joining the LSE, he was Associate Professor of Law at Universidad Torcuato Di Tella in Buenos Aires. He studied law at the Universidad de Buenos Aires before obtaining an LLM at Harvard Law School and later, an LLM on Tax Law at the LSE. He has been a Fulbright Scholar and a Chevening Scholar. He has also been a Distinguished Visiting Professor at Northwestern University and the University of Toronto. His research and publications are focused on international taxation. His current area of research is the tax treaty network and BRIC countries (Brazil, Russia, India and China).

    Ian Roxan, London School of Economics and Political Science
    Ian Roxan is an Associate Professor of Law and Director of the Tax Programme at the London School of Economics and Political Science.


    Ian Roxan, Eduardo Baistrocchi, Reuven S. Avi-Yonah, David G. Duff, Byron Beswick, Philip Gillett, Andreas Oestreicher, Violeta Ruiz Almendral, Richard Vann, Toshio Miyatake, Hun Park, Stephen Phua Lye Huat, Isabel Calich, Joao Dacio Rolim, Andrey Shpak, Mukesh Butani, Jinyan Li, Juan Pablo Guerrero Daw, Ofer Granot, Yoram Margalioth, Lee Corrick

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