This book outlines how the application of the arm?s length principle should be reconsidered in light of the initiative of the OECD and G20 to counter tax base e
The arm's length principle serves as the domestic and international standard to evaluate transfer prices between members of multinational enterprises for tax pu
This is the first book to present a sustained analysis and critique of arm's length based transfer pricing rules following the G20 / OECD Base Erosion and Profi
It is well known that intercompany financing arrangements have become increasingly subject to scrutiny in contexts of applying transfer pricing and anti-tax avo
The term ?location-specific advantages? (LSAs), including location savings and market premiums, is a novel concept originating from the transfer pricing practic