Table of Contents:
  • Part 1. The Roles and Functions of Transfer Pricing in Organisations
  • Transfer Pricing in Multinational Corporations: An Integrated Management- and Tax Perspective
  • Comment on Hiemann and Reichelstein: "Transfer Pricing in Multinational Corporations: An Integrated Management- and Tax Perspective"
  • Multiple Roles of Transfer Prices: One vs. Two Books
  • Transfer Pricing
  • Business Incentives, International Taxation and Corporate Law
  • Part 2. The OECD Approach to Transfer Pricing
  • Soft Law, Hard Realities and Pragmatic Suggestions: Critiquing the OECD Transfer Pricing Guidelines
  • The OECD Approach to Transfer Pricing: A Critical Assessment and Proposal
  • OECD Guidelines: Causes and Consequences
  • Reflecting on the "Arm's Length Principle": What is the "Principle"? Where Next?
  • Part 3. Transfer Pricing in Practice
  • Credit Ratings and the Debt-related Costs for a Subsidiary of a Multinational Firm
  • Transfer Pricing in the Courts: A Cross-Country Comparison
  • Comments on Julie Roin: "Transfer Pricing in the Courts: A Cross-Country Comparison"
  • Part 4. Separate Accounting, Profit Split and Formulary Apportionment
  • Assessing the Normative Differences Between Formula Apportionment and Separate Accounting
  • Profit Split, the Future of Transfer Pricing? Arm's Length Principle and Formulary Apportionment Revisited from a Theoretical and a Practical Perspective
  • In Favor of Formulary Apportionment A Comment on Kroppen/Dawid/Schmidtke: "Profit Split, the Future of Transfer Pricing? Arm's Length Principle and Formulary Apportionment Revisited from a Theoretical and a Practical Perspective."