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Comparative and Foreign Law

Series

2001

Transfer pricing

Articles 1 - 2 of 2

Full-Text Articles in Law

Transfer Pricing: A Comparative Study Of The French And U.S. Legal Systems, Valerie Ciancia Dec 2001

Transfer Pricing: A Comparative Study Of The French And U.S. Legal Systems, Valerie Ciancia

LLM Theses and Essays

For several decades, the number of multinational corporations has significantly increased and this phenomenon has created a new problem: the issue of transfer pricing. Indeed, national states have observed that multinationals could simply manipulate cross- border transfer pricing policies in order to shift profits from one jurisdiction to another. France, along with the United States, was one of the very first countries to introduce transfer-pricing legislations. Although the aims of the French and U.S. transfer pricing systems are similar, the means used to apply such rules are different and often raise difficulties to get rid of double taxations. Nevertheless, many …


Evolution Of The Arm's Length Standard In The Us Transfer Pricing Legislation And Russian Arm's Length Perspective, Andrei A. Shutov Jan 2001

Evolution Of The Arm's Length Standard In The Us Transfer Pricing Legislation And Russian Arm's Length Perspective, Andrei A. Shutov

LLM Theses and Essays

This thesis analyzes the evolution of the arm's length standard (ALS) as the key element of the transfer pricing control system in the US. This thesis also addresses some issues on creation of transfer pricing legislation in the Russian Federation and focuses on three sets of problems. First, it provides the general outline of the legislative history of the ALS as well as the history of the ALS' application in the US, including an overview of landmark cases, which revealed some conceptual problems with respect to the ALS. Secondly, the thesis addresses core problems associated with the ALS, such as …