International tax coordination has reached impressive results after the turn of the century. Multi-lateral agreements like the Common Reporting Standard or the BEPS Action Plan are clear signs of the willingness of a large number of states to cooperate in fiscal matters at a global scale....

Within the European Union, there exists a fundamental tension between the fiscal sovereignty of its Member States, in particular in the field of direct taxation, and the requirements of the Internal Market, which aim at the abolition of any regulatory or fiscal obstacles to cross border movement...

One of the aims of the BEPS Action Plan is to reduce existing leeway for multinational enterprises to shift profits by exploiting transfer pricing rules. Profit allocation is meant to be aligned with “real activity” and “value creation.” This article is devoted to the question of whether...

Transfer pricing is relevant in three different contexts: From a managerial perspective, intra-firm transfer prices are employed to set incentives for sub-divisional managers to enhance efficient allocation of resources. From an international tax perspective, transfer pricing rules under the...