In 1988, the US Treasury Department published a study of inter-company pricing (the \u27White Paper\u27) that included the following endorsement of the so-called arm\u27s length standard (ALS) for examining the reasonableness of transactions between related parties for tax purposes: The arm\u27s length standard is embodied in all U.S. tax treaties; it is in each major model treaty, including the U.S. Model Convention; it is incorporated into most tax treaties to which the United States is not a party; it has been explicitly adopted by international organizations that have addressed themselves to transfer pricing issues; and virtually every major industrial nation takes the arm\u27s length standard as its frame of reference in transfer prici...
Based on the court case analysis and expert interviews, we identify the key challenges in implementi...
The globalization, the international trade and the number of multinational enterprises have continue...
The arm’s length standard is used by corporate income tax authorities to price international intraco...
In 1988, the US Treasury Department published a study of inter-company pricing (the \u27White Paper\...
A revised and updated version of the 1995 article (Va. Tax Review) on the evolution of US transfer p...
This thesis analyzes the evolution of the arm\u27s length standard (ALS) as the key element of the t...
This article addresses some of the fundamental issues behind the current international tax policy de...
This article examines the current transfer pricing regime to consider whether it is a sound model to...
The European Court of Justice has confirmed the compatibility of transfer pricing adjustments under ...
The recent Altera case in the US Tax Court (on appeal to the Ninth Circuit) raises interesting issue...
This essay argues that the complete harmonisation of transfer pricing rules with the arm’s length pr...
This is the first book to present a sustained analysis and critique of arm's length based transfer p...
Via a global analysis of more than 180 transfer pricing cases from 20 representative jurisdictions, ...
Whenever goods cross national borders within the channels of a multina-tional corporation (MNC), a t...
This master’s thesis deals with the transfer pricing of intangibles and focuses on the U.S. standard...
Based on the court case analysis and expert interviews, we identify the key challenges in implementi...
The globalization, the international trade and the number of multinational enterprises have continue...
The arm’s length standard is used by corporate income tax authorities to price international intraco...
In 1988, the US Treasury Department published a study of inter-company pricing (the \u27White Paper\...
A revised and updated version of the 1995 article (Va. Tax Review) on the evolution of US transfer p...
This thesis analyzes the evolution of the arm\u27s length standard (ALS) as the key element of the t...
This article addresses some of the fundamental issues behind the current international tax policy de...
This article examines the current transfer pricing regime to consider whether it is a sound model to...
The European Court of Justice has confirmed the compatibility of transfer pricing adjustments under ...
The recent Altera case in the US Tax Court (on appeal to the Ninth Circuit) raises interesting issue...
This essay argues that the complete harmonisation of transfer pricing rules with the arm’s length pr...
This is the first book to present a sustained analysis and critique of arm's length based transfer p...
Via a global analysis of more than 180 transfer pricing cases from 20 representative jurisdictions, ...
Whenever goods cross national borders within the channels of a multina-tional corporation (MNC), a t...
This master’s thesis deals with the transfer pricing of intangibles and focuses on the U.S. standard...
Based on the court case analysis and expert interviews, we identify the key challenges in implementi...
The globalization, the international trade and the number of multinational enterprises have continue...
The arm’s length standard is used by corporate income tax authorities to price international intraco...