Resolving Transfer Pricing Disputes
A Global Analysis

This analysis provides novel insights into the resolution of transfer pricing disputes around the world.

Eduardo Baistrocchi (Edited by), Ian Roxan (Edited by)

9781107026599, Cambridge University Press

Hardback, published 6 December 2012

990 pages, 23 b/w illus. 34 tables
22.9 x 15.2 x 5.1 cm, 1.51 kg

'… the work's contribution to the international tax literature is ensured.' Diane M. Ring, Tax Notes International

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 pricing in Germany Andreas Oestreicher
7. Transfer pricing in Spain Violeta Ruiz Almendral
8. Transfer pricing disputes in the United Kingdom Ian Roxan
Part II. Asia-Pacific: 9. Transfer pricing disputes in Australia Richard Vann
10. Transfer pricing disputes in Japan Toshio Miyatake
11. Transfer pricing disputes in the Republic of Korea Hun Park
12. Transfer pricing in Singapore Stephen Phua Lye Huat
Part III. BRIC Countries: 13. Transfer pricing disputes in Brazil Isabel Calich and Joao Dacio Rolim
14. Transfer pricing disputes in the Russian Federation Andrey Shpak
15. Transfer pricing disputes in India Mukesh Butani
16. Transfer pricing disputes in China Jinyan Li
Part IV. South America, Middle East and Africa: 17. Transfer pricing disputes in Argentina Eduardo Baistrocchi
18. Transfer pricing disputes in Chile Juan Pablo Guerrero Daw
19. Transfer pricing disputes in Israel Ofer Granot and Yoram Margalioth
20. Transfer pricing disputes in Africa Lee Corrick
21. Transfer pricing dispute resolution: the global evolutionary path (1799–2011) Eduardo Baistrocchi
22. Resolving transfer pricing disputes: an analysis of the globe Ian Roxan.

Subject Areas: Arbitration, mediation & alternative dispute resolution [LNAC5], Taxation [KFFD1], Finance [KFF]