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Vol 21 No 11 Nov/Dec 2016

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Transfer Pricing and the Arm's Length Principle in International Tax Law


ISBN13: 9789041132703
Published: September 2010
Publisher: Kluwer Law International
Country of Publication: The Netherlands
Format: Hardback
Price: £128.00



Despatched in 10 to 12 days.

This book analyzes the legal basis for the arm's length principle and the contents of the principle in U.S. 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.

Subjects:
Taxation
Contents:
Part One - Introduction
Part Two – The Legal Basis for the Arm's Length Principle
U.S. Tax Law
OECD
Other International Law
Part Three – The Concept of the Arm's Length Principle
General
U.S. 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.

Series: International Taxation

Customs Valuation and Transfer Pricing 2nd ed ISBN 9789041161345
To be published March 2017
Kluwer Law International
£97.00
Taxation and Migration ISBN 9789041161369
Published October 2015
Kluwer Law International
£100.00
Taxation of Derivatives ISBN 9789041159779
Published August 2015
Kluwer Law International
£148.00
The VAT/GST Treatment of Public Bodies ISBN 9789041146632
Published January 2013
Kluwer Law International
£104.00
Science, Technology and Taxation ISBN 9789041131256
Published July 2012
Kluwer Law International
£104.00
£104.00
Immovable Property under VAT: A Comparative Global Analysis ISBN 9789041131263
Published May 2011
Kluwer Law International
£104.00
The International Tax Law Concept of Dividend 2nd ed ISBN 9789041132062
Published August 2010
Kluwer Law International
£104.00
Systems of General Sales Taxation: Theory, Policy and Practice ISBN 9789041128324
Published August 2009
Kluwer Law International
£119.00
Taxpayers Rights: Theory, Origin and Implementation ISBN 9789041126504
Published September 2007
Kluwer Law International
£163.00
Tax Treaty Law and EC Law ISBN 9789041126290
Published August 2007
Kluwer Law International
£119.00
Tax Investment Incentives in Foreign Direct Investment ISBN 9789041122285
Published April 2004
Kluwer Law International
£127.00
Customs Valuation and Transfer Pricing ISBN 9789041198884
Published December 2002
Kluwer Law International
£100.00
International and Comparative Taxation: Essays in Honour of Klaus Vogel ISBN 9789041198419
Published September 2002
Kluwer Law International
£100.00
£158.00
The Dividend Concept in International Tax Law ISBN 9789041197658
Published January 2000
Kluwer Law International
Out of print