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Full-Text Articles in Business
Apple, State Aid, And Arm’S Length: Eu General Court’S Failure Of Imagination, David G. Chamberlain
Apple, State Aid, And Arm’S Length: Eu General Court’S Failure Of Imagination, David G. Chamberlain
Accounting
In this article, Chamberlain analyzes the EU General Court ruling in Apple, and examines state aid and transfer pricing in the EU, with a focus on (and as an advocate for) the existence of an autonomous arm’s-length principle.
How The Tax Court Can Account For Risk In Medtronic Transfer Pricing, David G. Chamberlain
How The Tax Court Can Account For Risk In Medtronic Transfer Pricing, David G. Chamberlain
Accounting
In this report, Chamberlain explores how the Tax Court, on remand in Medtronic, can address the challenge of determining arm’s-length transfer prices when one of the related parties bears substantial risk but owns no valuable intangible property.