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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:
  • 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

List Price: HKD 1,840.00

HKD 1,784.80 Save HKD 55.20 (3%)

Delivery Time: around 2 weeks
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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

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