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Transfer Pricing and the Arm's Length Principle in International Tax Law

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Transfer Pricing and the Arm's Length Principle in International Tax Law Synopsis

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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

About This Edition

ISBN: 9789041132703
Publication date:
Author: Jens Wittendorff
Publisher: Kluwer Law International an imprint of Wolters Kluwer Law & Business
Format: Hardback
Pagination: 880 pages
Series: Series on International Taxation
Genres: Taxation and duties law