Transfer Pricing and the Arm's Length Principle in International Tax Law, Hardcover by Wittendorff, Jens, ISBN 9041132708, ISBN-13 9789041132703, Like New Used, Free shipping in the US
The proposed book analyzes the legal basis for the arm's length principle and the contents of the principle in . 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. Th consists of the following chapters: Part One - Introduction Part Two – The Legal Basis for the Arm's Length Principle . Tax Law OECD Other International Law Part Three – The Concept of the Arm's Length Principle General . 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