"Via a global analysis of more than 180 transfer pricing cases from 20 representative jurisdictions, Resolving Transfer Pricing Disputes explains how the law on transfer pricing operates in practice and examines how disputes between taxpayers and tax administrations are dealt with around the...

In this Part 3, we explore the KSA’s historic approach to penalties and the motivation to develop transfer pricing-specific penalties. For sake of illustration, we will review the IRS reasons for enactment of transfer pricing-specific penalties, the substance of those penalties, and the IRS...

As part of an increased openness to international investment and the resulting need to address international tax issues, the Kingdom of Saudi Arabia (KSA) recently adopted transfer pricing regulations consistent with global norms. Due to the newness of these regulations in the KSA tax system and...

The EU—Fatty Alcohols decision of the Appellate Body addressed an important issue of the scope of permissible adjustments under Article 2.4 of the Agreement on Interpretation of Article VI of the GATT 1994, focusing on the “mark-up” paid by an Indonesian exporter to a related company as a...

This chapter shows the evolutionary path of transfer pricing dispute resolution in twenty countries from the five continents since 1799. It consists of six core stages that encapsulate how the ALP has gradually evolved from being a rule-based regulation to a procedural, standard-based regulation...

This paper concerns the 2011 Australian Government's then proposed changes to the transfer pricing rules, referred to as the stage one amendments, and the consultation process to provide interested parties with an opportunity to comment. The paper covers the external submissions received, with a...

Under Action 14, countries have committed to implement a minimum standard to strengthen the effectiveness and efficiency of the mutual agreement procedure (MAP). The MAP is included in Article 25 of the OECD Model Tax Convention and commits countries to endeavour to resolve disputes related to...

Under Action 14, countries have committed to implement a minimum standard to strengthen the effectiveness and efficiency of the mutual agreement procedure (MAP). The MAP is included in Article 25 of the OECD Model Tax Convention and commits countries to endeavour to resolve disputes related to...