You are not logged in.

The arm’s length comparable in transfer pricing: a search for an “actual” or a “hypothetical” transaction?

Pichhadze, Amir 2015, The arm’s length comparable in transfer pricing: a search for an “actual” or a “hypothetical” transaction?, World Tax Journal, vol. 7, no. 3.

Attached Files
Name Description MIMEType Size Downloads

Title The arm’s length comparable in transfer pricing: a search for an “actual” or a “hypothetical” transaction?
Author(s) Pichhadze, AmirORCID iD for Pichhadze, Amir orcid.org/0000-0003-1686-2601
Journal name World Tax Journal
Volume number 7
Issue number 3
Total pages 28
Publisher International Bureau of Fiscal Documentation
Place of publication Netherlands
Publication date 2015
ISSN 1878-4917
Summary When searching for an arm’s length comparable in the transfer pricing analysis, does the analysis require (or allow) searching for a transaction that actually took place in the market, or can/should the internal data of the controlled transaction simply be imputed to form a hypothetical uncontrolled transaction in which the parties are assumed to be operating at arm’s length but otherwise dealing under the same circumstances? This article sheds light on this question, based on lessons distilled from recent Canadian jurisprudence; particularly, the case Canada v. GlaxoSmithKline Inc. The author calls on Canada’s courts to reconsider their approach to this issue, and alerts courts in other jurisdictions to avoid transplanting the Canadian approach because otherwise they would risk repeating the same mistake(s).
Language eng
Field of Research 1501 Accounting, Auditing And Accountability
1801 Law
Socio Economic Objective 0 Not Applicable
HERDC Research category C1.1 Refereed article in a scholarly journal
ERA Research output type C Journal article
Copyright notice ©2015 IBFD
Persistent URL http://hdl.handle.net/10536/DRO/DU:30097357

Document type: Journal Article
Collections: Law
Training - Quality check
Connect to link resolver
 
Unless expressly stated otherwise, the copyright for items in DRO is owned by the author, with all rights reserved.

Versions
Version Filter Type
Citation counts: TR Web of Science Citation Count  Cited 0 times in TR Web of Science
Scopus Citation Count Cited 0 times in Scopus
Google Scholar Search Google Scholar
Access Statistics: 49 Abstract Views, 0 File Downloads  -  Detailed Statistics
Created: Fri, 23 Jun 2017, 14:40:18 EST

Every reasonable effort has been made to ensure that permission has been obtained for items included in DRO. If you believe that your rights have been infringed by this repository, please contact drosupport@deakin.edu.au.