Resolving Transfer Pricing Disputes A Global Analysis [Hardcover]

This analysis provides novel insights into the resolution of transfer pricing disputes around the world.This book explains transfer pricing through a global study of disputes and the implications of innovative dispute resolution methods. It discusses twenty representative jurisdictions and analyses multiple transfer pricing disputes from North and South America, Europe, Asia and Africa, including all four BRIC countries.This book explains transfer pricing through a global study of disputes and the implications of innovative dispute resolution methods. It discusses twenty representative jurisdictions and analyses multiple transfer pricing disputes from North and South America, Europe, Asia and Africa, including all four BRIC countries.Via a global analysis of more than 180 transfer pricing cases from 20 representative jurisdictions, Resolving Transfer Pricing Disputes explains how the law on transfer pricing operates in practice and examines how disputes between taxpayers and tax administrations are dealt with around the world. It has been designed to be an essential complement to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, which focus on transfer pricing issues but do not refer to specific transfer pricing disputes. All of the transfer pricing cases discussed in the book are linked to the relevant paragraphs of the OECD Guidelines by means of a 'Golden Bridge', namely a table listing the cases according to the paragraphs of the Guidelines to which they refer. It therefore provides examples of the application of the Arm's Length Principle in many settings on all continents.1. Introduction Ian Roxan; 2. The transfer pricing problem Eduardo Baistrocchi; Part I. North America and Europe: 3. Transfer pricing disputes in the United States of America Reuven S. Avi-Yonah; 4. Transfer pricing disputes in Canada David G. Duff and Byron Beswick; 5. Transfer pricing disputes in the European Union Philip Gillett; 6. Transfer pricinlõ