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Transfer pricing and the arm's length principle in international tax law.


Transfer pricing and the arm's length principle in international tax law.

Wittendorff, Jens.

Kluwer Law International


880 pages



Series on international taxation; v.35


In international tax law, the arm's length principle states that multinational enterprises should carry out controlled transactions at arm's length prices, or prices which associated enterprises would have agreed to if they had made a comparable transaction on the open market rather than the controlled transaction that was in fact made in order that taxation may be levied in relation to the hypothetical "normal" transaction. Limited to discussion of the kinds of transactions specifically covered by the guidelines of the Organisation for Economic Co-operation and Development, his treatise addresses the problems associated with transfer pricing that arise from the fact that the allocation of profit under the arm's length principle depends on the transfer price of the controlled transaction; problems that concern the allocation of profits between taxpayers with common interest, international income allocation between states, requirements for information and documentation, and the risk of international double taxation. This volume originated as Wittendorff's doctor of jurisprudence dissertation on the arm's length principle, Armslaengdeprincippet i dansk og international skatteret, completed at the U. of Aarhus in Denmark. It is an English translation that differs from the original dissertation primarily by omission the chapter on the legal basis for the principle in domestic Danish tax law and by having been updated to reflect changes that have taken place between the September 2008 completion of the dissertation and May 2010. Distributed in North America by Aspen Publishers, Inc.

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Article Type:Book review
Date:Apr 1, 2011
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