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

See all articles by Eduardo A. Baistrocchi

Eduardo A. Baistrocchi

London School of Economics - Law Department

Date Written: October 8, 2012

Abstract

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

Suggested Citation

Baistrocchi, Eduardo A., Transfer Pricing Dispute Resolution: The Global Evolutionary Path (October 8, 2012). Eduardo A Baistrocchi and Ian Roxan (eds), Resolving Transfer Pricing Disputes: A Global Analysis (Cambridge University Press 2012) . Available at SSRN: https://ssrn.com/abstract=2337717

Eduardo A. Baistrocchi (Contact Author)

London School of Economics - Law Department ( email )

Houghton Street
London, WC2A 2AE
United Kingdom

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