Fundamentals of Transfer Pricing: General Topics and Specific Transactions

With approximately 160 practical examples and 90 relevant international judicial precedents, the presentation proceeds from general to more specialised topics. Such aspects of the subject as the following are thoroughly analysed:

• what is transfer pricing and the purpose of transfer pricing rules;
• the arm’s length principle and its application;
• the consequences of a transaction not being in accordance with the arm’s length principle;
• the transfer pricing methods;
• the mechanisms to avoid and resolve disputes;
• the transfer pricing documentation;
• the attribution of profits to permanent establishments;
• the transfer pricing aspects of specific transactions, such as services, financing, intangibles and business restructurings.

The application of transfer pricing legislation is arguably the most difficult task that taxpayers and tax authorities around the world must face. With this authoritative source of practical guidance, government officials, tax lawyers, in-house tax counsel, academics, advisory firms, the business community and other stakeholders worldwide will have all the detail they need to move forward in tackling this thorny aspect of the current tax environment.