This paper forms one of a series examining aspects of transfer pricing from a Japanese perspective. In earlier work the authors examined prevalent allegations that global companies, especially Japanese multinationals, operated transfer pricing policies to the deliberate disadvantage of host...

This paper examines the difficulties facing tax authorities in valuing cross-border flows from a transactions based analysis, in conditions where intangibles and services are important and where the multinational firm concerned is operating a system in which group-wide economic functions...