The taxation of multinational corporate groups has become a
major concern in the academic and political debate on the future of
international taxation. In particular the arm's length standard for
the determination of transfer prices is under increasing
pressure.
Many countries and international bodies are now taking a closer
look at the use of transfer prices for profit shifting and are
exploring alternative mechanisms such as formulary apportionment
for the allocation of taxing rights.
With regard to this topic, this volume is the first to offer a
concise analysis of transfer pricing in the international tax arena
from an interdisciplinary legal and economic point of view.
Fundamentals such as the efficient allocation of resources within
multi-unit firms and distortions between different goals of
transfer pricing as well as different aspects of it in tax and
corporate law, the traditional OECD approach and practical aspects
concerning intangibles, capital and risk allocation are covered by
outstanding authors.
General
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