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

It is well known that intercompany financing arrangements have become increasingly subject to scrutiny in contexts of applying transfer pricing and anti-tax avo

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

Transfer pricing is one of the most relevant and challenging topics in international taxation. Over the last century, nearly every country in the world introduc