Fundamentals of Transfer Pricing

Volume 1: Principles and Practice

Edited by Raffaele Petruzzi, Giammarco Cottani & Michael Lang

Transfer pricing is one of the most important and complex topics in international taxation. Recognising its significance, most countries in the world have introduced transfer pricing rules in their domestic tax systems. This book, the first of a three-volume series, explains in a clear and simple manner the most important transfer pricing topics, with a collection of incisive and wide-ranging perspectives from representatives of academia, tax law practice, multinational companies, advisory groups, national tax authorities, and international organisations from all over the globe.

The contributions collectively offer a comprehensive guide to the practical application of transfer pricing rules, covering various aspects as the following:

introduction to transfer pricing;
accurate delineation and recognition of actual transactions;
transfer pricing methods;
comparability analysis;
transfer pricing audits and litigation;
administrative approaches to preventing and resolving transfer pricing disputes;
transfer pricing documentation;
attribution of profits to permanent establishments;
transfer pricing and specific transactions;
use of new technologies in transfer pricing; and
interplay between transfer pricing and other rules.

This book delves into both foundational concepts and emerging trends in transfer pricing, providing readers with the tools to understand its dynamic application in real-world scenarios. By analysing examples, case studies, and the implications of recent judicial precedents, it bridges the gap between fundamental principles and practical implementations.

The application of transfer pricing legislation remains one of the most challenging tasks for taxpayers and tax authorities around the world. With this comprehensive source of practical guidance, tax lawyers, in-house tax counsels, government officials, academics, advisory firms, and the business community worldwide will have all the support they need to move forward in tackling this complex aspect of the current tax environment.