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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