Fundamentals of International Transfer Pricing in Law and Economics

  • Wolfgang Schön
  • Kai A. Konrad
Part of the MPI Studies in Tax Law and Public Finance book series (MPISTUD, volume 1)

Table of contents

  1. Front Matter
    Pages I-XIII
  2. The Roles and Functions of Transfer Pricing in Organisations

  3. The OECD Approach to Transfer Pricing

  4. Transfer Pricing in Practice

    1. Front Matter
      Pages 157-157
  5. Transfer Pricing in Practice

  6. Separate Accounting, Profit Split and Formulary Apportionment

    1. Front Matter
      Pages 255-255
  7. Separate Accounting, Profit Split and Formulary Apportionment

About this book

Introduction

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.

Keywords

Arm's Length Principle Formulary Apportionment International Taxation OECD Transfer Pricing Guidelines Transfer Pricing

Editors and affiliations

  • Wolfgang Schön
    • 1
  • Kai A. Konrad
    • 2
  1. 1.for Tax Law and Public Finance, Business and Tax LawMax Planck InstituteMunichGermany
  2. 2.for Tax Law and Public Finance, Public FinanceMax Planck InstituteMunichGermany

Bibliographic information

  • DOI https://doi.org/10.1007/978-3-642-25980-7
  • Copyright Information Springer-Verlag Berlin Heidelberg 2012
  • Publisher Name Springer, Berlin, Heidelberg
  • eBook Packages Humanities, Social Sciences and Law
  • Print ISBN 978-3-642-25979-1
  • Online ISBN 978-3-642-25980-7
  • About this book