Location-Specific Advantages : A Rising Disruptive Factor in Transfer Pricing
Bulletin for International Taxation. - Amsterdam. - Vol. 71 (2017), no. 5 ; p. 259-271; DOI: https://doi.org/10.59403/bx6n4e
Posted: 11 Apr 2024
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Location Specific Advantages: A Rising Disruptive Factor in Transfer Pricing
Location-Specific Advantages : A Rising Disruptive Factor in Transfer Pricing
Date Written: March 22, 2017
Abstract
In this article, the authors consider location-specific advantages (LSAs) in transfer pricing analysis, with a special emphasis on the practice in China. They suggest that LSAs disrupt some of the basic assumptions underlying the current consensus on the application of the arm's length principle without, arguably, violating the purpose of the principle as stated in article 9 of the OECD Model.
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Keywords: transfer pricing, location savings, arm's length principle
JEL Classification: K33, K34
Suggested Citation: Suggested Citation