Introduction to Transfer Pricing 2Ed.

ntroduction to Transfer Pricing, currently in its second edition, is a book that intends to introduce the fundamentals of transfer pricing. Although the book relies mainly on the OECD Transfer Pricing Guidelines, the views of other international organisations – in particular, the United Nations and the European Union – are also considered. In addition, the book illustrates the fundamentals of transfer pricing with concrete examples based on the business models often used by multinational enterprises. Relevant court cases from various countries are also included.

The following issues and topics have been discussed in this book:

the arm’s length principle in theory and practice transfer pricing methods intercompany transactions involving intangibles and financial transactions common types of transfer pricing models cross-border business restructurings the substance requirement for transfer pricing purposes attribution of profits to permanent establishments, and the prevention and resolution of transfer pricing disputes
This second edition was updated based on the 2022 OECD Transfer Pricing Guidelines and the 2021 UN Transfer Pricing Manual.

This timely book provides an easily accessible yet deep enough introduction to one of the most important international tax issues for multinational enterprises and tax administrations. The book will be of great use for students, practitioners, government officials and judges.