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Articles 1 - 2 of 2
Full-Text Articles in European Law
The Specter Of Civil Law Clawback Actions Haunting U.S. And Uk Charitable Giving, Aaron Schwabach
The Specter Of Civil Law Clawback Actions Haunting U.S. And Uk Charitable Giving, Aaron Schwabach
Faculty Scholarship
No abstract provided.
Transfer Pricing: The Cup -- Case Studies: Australia, Us, Uk, Norway And Canada, Richard Thompson Ainsworth, Andrew Shact
Transfer Pricing: The Cup -- Case Studies: Australia, Us, Uk, Norway And Canada, Richard Thompson Ainsworth, Andrew Shact
Faculty Scholarship
All transfer pricing regimes give priority to the comparable uncontrolled price (CUP) method. Despite declarations that transfer pricing is a search for the “best method” or “most appropriate method,” all systems concede that the search is over when an exact comparable is found because a CUP is preferred over all methods. The best CUP is an exact CUP because it provides an arm’s length price that is not calculated. The price emerges directly from the comparison.
CUPs have traditionally been the most commonly applied method for both taxpayers and the government. They are the judicial gold standard. They hold sway …