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

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