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Transfer priing and economic functions analysis: the Japanese paradigm

Buckley, Peter J. and Frecknall Hughes, Jane (2000). Transfer priing and economic functions analysis: the Japanese paradigm. In: Buckley, Peter J. ed. Multinational Firms, Cooperation and Competition in the World Economy. Basingstoke, U.K.: Palgrave Macmillan, pp. 123–143.

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This paper examines the difficulties facing tax authorities in valuing cross-border flows from a transactions based analysis, in conditions where intangibles and services are important and where the multinational firm concerned is operating a system in which group-wide economic functions dominate decision making. Its key contention is that the economic functions of any entity should be examined in order to determine whether transactions analysis can be used to produce an acceptable value. This is done in the particular context of Japanese multinational enterprises and uses two hypothetical situations to demonstrate the inadequacy of transactions based analysis as a panacea for transfer pricing problems, especially for transfers of value involving intangibles and services, which it redefines into two categories, perceptible and imperceptible.

Item Type: Book Section
Copyright Holders: 2000 Macmillan
ISBN: 0-333-75977-X, 978-0-333-75977-6
Academic Unit/School: Faculty of Business and Law (FBL)
Related URLs:
Item ID: 25071
Depositing User: Catherine Playle
Date Deposited: 22 Mar 2011 16:07
Last Modified: 02 May 2018 13:20
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