The objective of this paper is to analyze the procedures used by multinational enterprises to distribute the income generated by its foreign subsidiaries, and how they allocate the taxes paid on this income through the fiscal jurisdiction in which they operate, from the institution based view....

This chapter from a Practical Guide to Transfer Pricing (Lexis) compares the U.S. Section 482 transfer pricing regulations to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations as revised in 2010. Section 482's purpose is to ensure that taxpayers subject...

The overwhelming complexity of transfer pricing within income taxation and the number of available materials generates significant entry barriers for conducting adequate research in this field. The objective of this contribution is to briefly depict the most relevant issues and provide basic...

This paper analyzes the effect on firm behavior and national tax revenues of a policy of allowing multinational firms to choose whether to be taxed under separate accounting rules (transfer prices) or an apportionment formula. Either method can be preferred by low-cost firms and by high-cost...

When a Canadian parent corporation guarantees a debt obligation incurred by its foreign affiliate subsidiary, the issue arises whether the Canadian transfer pricing rules require the Canadian parent to receive an arm's length guarantee fee from the foreign affiliate. Proposed subsection 247(7.1)...

Finding common ground between corporate tax compliance and enforcement appears difficult and expensive, judging by the current inventory of almost $200 billion in proposed IRS transfer pricing tax adjustments, and projections of as much as $100 billion or more in annual U.S. federal corporate...

This article assesses the desirability of our current, arms' length based, transfer pricing regime by analyzing its theoretical and practical effectiveness in application to transfers of intangibles. A detailed analysis of the practice of valuation of intangibles, which is the key component in...