Long awaited final regulations on transfer pricing penalties were published on February 9, 1996. The 1994 temporary … approach than the OECD transfer pricing guidelines. The final regulations continued to disappoint by requiring taxpayers to …

In response to developments in international trade and an increased focus on international transfer-pricing issues … transfer-pricing provisions in the Income Tax Act. On September 11, 1997, the Department of Finance released draft transfer-pricing …’s international transfer-pricing practices. In particular, they attempt to harmonize the standards in the Income Tax Act with the arm …

This study investigates how strategic tax transfer pricing of a multinational company (MNC) and two tax authorities in … employ a game-theoretical model to analyze the costs and benefits of two tax transfer pricing regimes (consistency vs …. inconsistency) under asymmetric information. Though tax transfer pricing harmonization is considered a promising instrument to fight …

particular focus on the needs of low-capacity countries. Content from the report has now been incorporated into the OECD Transfer … Pricing Guidelines. …