Resolving Transfer Pricing Disputes

Taxation › International › Transfer Pricing

Resolving Transfer Pricing Disputes A Global Analysis

Edited by Edited by Eduardo Baistrocchi · Dr Ian Roxan
Cambridge University Press November 2012

Specifications

ISBN-13
9781107026599
Publisher
Cambridge University Press
Publication
November 2012
Format
Hardback , 976 pages
Jurisdiction
Brazil, China, Germany, India, International, Japan, Russia, U.K., U.S. ? Countri(es) for reference only

Details

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

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.

About the Author

Eduardo Baistrocchi
London School of Economics and Political Science

Dr Ian Roxan
London School of Economics and Political Science

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