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Resolving Transfer Pricing Disputes

Resolving Transfer Pricing Disputes A Global Analysis

Author: Edited by Eduardo Baistrocchi; Dr Ian Roxan
Publisher: Cambridge University Press
ISBN: 9781107026599
Published In: November 2012
Format: Hardback , 976 pages
Jurisdiction: Brazil, China, Germany, India, International, Japan, Russia, U.K., U.S. ? Disclaimer:
Countri(es) stated herein are used as reference only

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Contents
Author

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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.

• 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

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;