Resolving Transfer Pricing Disputes

Resolving Transfer Pricing Disputes

Author: edited by Eduardo Baistrocchi, Ian Roxan
Publisher: Cambridge University Press
Category: Law

Via a global analysis of more than 180 transfer pricing cases from 20 representative jurisdictions, Resolving Transfer Pricing Disputes explains how the law on transfer pricing operates in practice and examines how disputes between taxpayers and tax administrations are dealt with around the world. It has been designed to be an essential complement to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, which focus on transfer pricing issues but do not refer to specific transfer pricing disputes. All of the transfer pricing cases discussed in the book are linked to the relevant paragraphs of the OECD Guidelines by means of a ‘Golden Bridge’, namely a table listing the cases according to the paragraphs of the Guidelines to which they refer. It therefore provides examples of the application of the Arm’s Length Principle in many settings on all continents.

About The Author

Eduardo Baistrocchi is an Associate Professor of Law at the London School of Economics and Political Science, having joined in 2009. Before joining the LSE, he was Associate Professor of Law at Universidad Torcuato Di Tella in Buenos Aires. He studied law at the Universidad de Buenos Aires before obtaining an LLM at Harvard Law School and later, an LLM on Tax Law at the LSE. He has been a Fulbright Scholar and a Chevening Scholar. He has also been a Distinguished Visiting Professor at Northwestern University and the University of Toronto. His research and publications are focused on international taxation. His current area of research is the tax treaty network and BRIC countries (Brazil, Russia, India and China).

Ian Roxan is an Associate Professor of Law and Director of the Tax Programme at the London School of Economics and Political Science.