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Transfer Pricing and the Arm's Length Principle in International Tax Law

Transfer Pricing and the Arm's Length Principle in International Tax Law

Author: Jens Wittendorff
Publisher: Kluwer Law International
ISBN: 9789041132703
Published In: August 2010
Format: Hardback , 912 pages
Jurisdiction: Australia, Canada, Denmark, France, Germany, International, Netherlands, Norway, Sweden, U.K., U.S. ? Disclaimer:
Countri(es) stated herein are used as reference only

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Description
Contents

Details
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
Part Three – The Concept of the Arm's Length Principle
- General
- U.S. Tax Law
- German Tax Law
- Article 9(1) of the OECD Model
Part Four – General Arm's Length Rules
- 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
Part Five – Special Arm's Length Rules
- Services
- Cost Sharing
- Intangibles
Part Six – Transfer Pricing Methods
- General
- Transfer Pricing Methods
Part Seven - Conclusion
Preface and Acknowledgement Abbreviations

Part I Introduction

Chapter 1 The Subject, Definitions, Methodology, and Plan for the Book

Part II The Legal Basis for the Arm's Length Principle

Chapter 2 U.S. Tax Law Chapter 3 The OECD Chapter 4 Other International Law

Part III The Concept of the Arm's Length Principle

Chapter 5 Introduction

Chapter 6 U.S. Tax Law

Chapter 7 Discourse: German Tax Law

Chapter 8 Article 9(1) of the OECD Model

Part IV General Arm's Length Rules

Chapter 9 Recognition of Controlled Transactions

Chapter 10 Aggregated and Separate Arm's Length Tests

Chapter 11Set-Off

Chapter 12 Multiple Year Analyses

Chapter 13 The Comparability Requirement

Chapter 14 Legislative Restrictions

Chapter 15 Arm's Length Range

Part V The Special Arm's Length Rules

Chapter 16 Services

Chapter 17 Cost Sharing

Chapter 18 Intangibles

Part VI Transfer Pricing Methods

Chapter 19 General

Chapter 20 Transfer Pricing Methods

Part VII Conclusion

Chapter 21 Summary and Discussion Bibliography Table of Cases Table of Official Reports Table of Statutes Index