Resolving Transfer Pricing Disputes: A Global Analysis

Resolving Transfer Pricing Disputes: A Global Analysis
ISBN-10
1139916289
ISBN-13
9781139916288
Category
Law
Language
English
Published
2012-12-06
Publisher
Cambridge University Press
Authors
Eduardo Baistrocchi, Ian Roxan

Description

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.

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