Transfer Pricing

FOREWORD

The field of transfer pricing is perceived as extraordinarily complex and resembles a jungle of regulations worldwide in which only specialists know their way around, although in principle everything could be reduced to a globally unified standard: the arm’s length principle. According to this principle, cross-border business relationships between related parties or transactions between associated enterprises should be established as if they were conducted with a third party for tax purposes and thus for the allocation of taxation rights to different countries. Consequently, a market-conform action should be introduced into a multinational enterprise group, the economic unit of the group of companies should be partially ignored and the individual associated business units should be taxed on the basis of the separate entity approach. In order to ensure this, countries around the world have issued regulations. International standard setters such as the OECD or UN have drawn up extensive guidelines.

It was difficult for us to enter this world and we would have liked to have had a manageable and practical book to help us get started. In view of this background we want to offer a...