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International Transfer Pricing Journal

Published/Hosted by International Bureau of Fiscal Documentation, The Netherlands. ISSN: 1385-3074.

The International Transfer Pricing Journal represents a worldwide view on transfer pricing issues for corporate tax purposes. Its approach is to combine reports on important domestic transfer pricing developments with analytical and comparative surveys of topics within the transfer pricing sphere. Benefits: Different perspectives are provided in substantial country surveys written by respected local specialists; Input from OECD and other countries ensures that coverage is truly global; Country-by-country analysis of issues in transfer pricing. Main contents: Articles and surveys about: transfer pricing between head office and permanent establishment; deductibility of head office costs; interest-free loans, trademarks, penalties; losses and the arm's length principle; the allocation of functions and risks within multinational enterprises; the tax treatment of management fees; the cost-plus method; the definition of associated enterprises; confidentiality of tax settlements and taxpayer information; the practical application of transactional profit methods; cost sharing arrangements; cost contribution arrangements; transfer pricing aspects of electronic commerce; international aspects of transfer pricing litigation; and transfer pricing when losses arise; Detailed articles on topical issues in the field and reports on worldwide developments. The latter include translations of, and comments on, recent government documents, case reports, and assessments of recent events in transfer pricing. Countries covered: Comparative country surveys undertaken globally, amongst others, include: Argentina, Australia, Belgium, Brazil, Canada, Estonia, France, Germany, Hungary, India, Ireland, Israel, Italy, Japan, Korea, Luxembourg, Mexico, the Netherlands, Pakistan, the Philippines, Portugal, Romania, Russia, South Africa, Spain, the United Kingdom, the United States and Uruguay.

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