Includes bibliographical references and index.

Introduction to transfer pricing -- Accurate delineation and recognition of actual transactions : comparability analysis -- Transfer pricing methods (part I) : traditional transaction methods -- Transfer pricing methods (part II) : transactional profit methods --Administrative approaches to avoid/minimizing transfer pricing disputes -- Administrative approaches to avoiding/minimizing transfer pricing disputes -- Administrative approach to resolving transfer pricing disputes -- Transfer pricing documentation: master file, local file and country-by-country reporting -- Attribution of profits to permanent establishments -- Transfer pricing and intra-group services -- Transfer pricing and intra-group financial transactions --Transfer pricing and intangibles -- Transfer pricing, supply chain management and business restructurings -- Transfer pricing and customs valuation -- Transfer pricing and EU state aid.

Transfer pricing continues to be one of the most significant areas of heightened controversy in international taxation for multinational enterprises and tax administrations. Due to its far-reaching consequences, tax professionals and individual tax jurisdictions are required to understand the fundamentals of the topic, which is often caught in a maze of literature. Emerging from the joint research conducted by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), the international tax law firm L&P - Ludovici Piccone & Partners, and the experiences from the annual advanced transfer pricing courses and conferences, this first edition of the book acts as a manual for understanding transfer pricing principles and their practical application. It provides a balanced approach by first detailing the basics of transfer pricing and second proceeding to specific topics that are highly relevant in today's tax environment. In analysing the topics, the work undertaken by the OECD, UN, EU, World Customs Organization, World Bank, International Monetary Fund and other international organizations is considered. Moreover, the book contains several practical examples, judicial precedents and illustrative explanations to complement the understanding.