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