Location-Specific Advantages : A Rising Disruptive Factor in Transfer Pricing

Posted: 11 Apr 2024

See all articles by Jinyan Li

Jinyan Li

York University - Osgoode Hall Law School

Stephen Ji

affiliation not provided to SSRN

Multiple version iconThere are 2 versions of this paper

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.

Full-text Paper

Keywords: transfer pricing, location savings, arm's length principle

JEL Classification: K33, K34

Suggested Citation

Li, Jinyan and Ji, Stephen, Location-Specific Advantages : A Rising Disruptive Factor in Transfer Pricing (March 22, 2017). Bulletin for International Taxation. - Amsterdam. - Vol. 71 (2017), no. 5 ; p. 259-271; DOI: https://doi.org/10.59403/bx6n4e, Available at SSRN: https://ssrn.com/abstract=4787598

Jinyan Li (Contact Author)

York University - Osgoode Hall Law School ( email )

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Stephen Ji

affiliation not provided to SSRN

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