Publisher's Synopsis
Now also available as eBook
The proposed book analyzes the legal basis for the arm's length principle and the contents of the principle in U.S. tax law as well as the OECD Model Tax Convention and Transfer Pricing Guidelines. It includes a thorough review of international case law on transfer pricing from the US., Canada, Australia, United Kingdom, Germany, France, the Netherlands, Denmark, Sweden and Norway.
The book consists of the following chapters: Part One - Introduction Part Two – The Legal Basis for the Arm's Length Principle
- U.S. Tax Law
- OECD
- Other International Law
- General
- U.S. Tax Law
- German Tax Law
- Article 9(1) of the OECD Model
- Recognition of the Controlled Transaction
- Combined and Separate Arm's Length Test
- Set-Offs
- Multiple Year Analysis
- Comparability Requirement
- Foreign Legal Restrictions
- Arm's Length Range
- Services
- Cost Sharing
- Intangibles
- General
- Transfer Pricing Methods
