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The proposed 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.
The book consists of the following chapters: Part One - Introduction
Part Two – The Legal Basis for the Arm's Length Principle
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U.S. Tax Law
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OECD
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Other International Law
Part Three – The Concept of the Arm's Length Principle
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General
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U.S. Tax Law
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German Tax Law
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Article 9(1) of the OECD Model
Part Four – General Arm's Length Rules
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Recognition of the Controlled Transaction
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Combined and Separate Arm's Length Test
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Set-Offs
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Multiple Year Analysis
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Comparability Requirement
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Foreign Legal Restrictions
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Arm's Length Range
Part Five – Special Arm's Length Rules
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Services
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Cost Sharing
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Intangibles
Part Six – Transfer Pricing Methods
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General
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Transfer Pricing Methods
Part Seven - Conclusion
Preface and Acknowledgement
Abbreviations
Part I Introduction
Chapter 1 The Subject, Definitions, Methodology, and Plan for the Book
Part II The Legal Basis for the Arm's Length Principle
Chapter 2 U.S. Tax Law
Chapter 3 The OECD
Chapter 4 Other International Law
Part III The Concept of the Arm's Length Principle
Chapter 5 Introduction
Chapter 6 U.S. Tax Law
Chapter 7 Discourse: German Tax Law
Chapter 8 Article 9(1) of the OECD Model
Part IV General Arm's Length Rules
Chapter 9 Recognition of Controlled Transactions
Chapter 10 Aggregated and Separate Arm's Length Tests
Chapter 11Set-Off
Chapter 12 Multiple Year Analyses
Chapter 13 The Comparability Requirement
Chapter 14 Legislative Restrictions
Chapter 15 Arm's Length Range
Part V The Special Arm's Length Rules
Chapter 16 Services
Chapter 17 Cost Sharing
Chapter 18 Intangibles
Part VI Transfer Pricing Methods
Chapter 19 General
Chapter 20 Transfer Pricing Methods
Part VII Conclusion
Chapter 21 Summary and Discussion
Bibliography
Table of Cases
Table of Official Reports
Table of Statutes
Index