Transfer Pricing Dispute Resolution: The Global Evolutionary Path
Eduardo A Baistrocchi and Ian Roxan (eds), Resolving Transfer Pricing Disputes: A Global Analysis (Cambridge University Press 2012)
49 Pages Posted: 10 Oct 2013 Last revised: 9 Aug 2018
Date Written: October 8, 2012
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 over the last century. The main driving force of this transformation is probably the ALP adaptation to two central technological innovations: the emergence of multinational enterprises over the first globalization (1850-1914) and, then, the emergence of the international trade in intangibles during the second globalization (1945 to the present).
Keywords: Transfer Pricing Disputes, Global Analysis
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