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|Introduction to Transfer Pricing, currently in its second edition, is a book that intends to introduce the fundamentals of transfer pricing. Although the book relies mainly on the OECD Transfer Pricing Guidelines, the views of other international organisations – in particular, the United Nations and the European Union – are also considered. In addition, the book illustrates the fundamentals of transfer pricing with concrete examples based on the business models often used by multinational enterprises. Relevant court cases from various countries are also included.
A foreword to this book is provided by Prof. Michael Lang.
What’s in this book:
The following issues and topics have been discussed in this book:
the arm’s length principle in theory and practice;
transfer pricing methods;
intercompany transactions involving intangibles and financial transactions;
common types of transfer pricing models;
cross-border business restructurings;
the substance requirement for transfer pricing purposes;
attribution of profits to permanent establishments; and
the prevention and resolution of transfer pricing disputes.
This second edition was updated based on the 2022 OECD Transfer Pricing Guidelines and the 2021 UN Transfer Pricing Manual.
How this will help you:
This timely book provides an easily accessible yet deep enough introduction to one of the most important international tax issues for multinational enterprises and tax administrations. The book will be of great use for students, practitioners, government officials and judges.
Table Of Contents
About the Author
List of Abbreviations
List of Figures
List of Tables
Preface to the Second Edition
Preface to the First Edition
The Key to Understanding Transfer Pricing: The Arm’s Length Principle
Transfer Pricing Methods
Transfer Pricing Models
Cross-Border Business Restructurings
The Substance Requirement from a Transfer Pricing Perspective
The Attribution of Profits to Permanent Establishments
Administrative Aspects: Compliance Issues and Transfer Pricing Disputes
Table of Cases
Table of Legislation