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NEW book: Transfer Pricing and Value Creation

Recently published:

Transfer Pricing and Value Creation,


Dear Colleagues,

The Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business), is pleased to inform you about our most recent publication:Petruzzi/Tavares (Eds.)

Transfer Pricing and Value Creation

Linde Verlag 2019. Series on International Tax Law, vol. nr. 116
ISBN: 9783707341232

Value Creation and its effects on Transfer Pricing and tax law

Emerging from the OECD/G20 BEPS Project, a new, somewhat fuzzy notion of Value Creation came to permeate not only Transfer Pricing language but also wider allocation rules and anti-abuse provisions in international tax law. The notion of ‘Value Creation’ reframes the interpretation and application of the Arm’s Length Principle (ALP) that is embedded in Articles 7 and 9 of the OECD Model Convention. This new Value Creation notion and approach assist in understanding key enterprise functions while different industry sectors manifest these concepts in various ways.

Situating such notions and this approach within the law of tax treaties and analyzing terms of the OECD Transfer Pricing Guidelines alongside their factual context is the aim of this book.

Here, law students address Transfer Pricing and Value Creation in sectors as varied as commodities trade, automotive, consumer products, food and beverages, pharmaceutical and life sciences, telecommunications, and the key topic of value creation in a digitalized economy.

Our LL.M. students were required to address issues not explored in legal research and to discuss factual topics relevant for Transfer Pricing.

All students focused on topics that are new to the international tax debate that keep evolving and on factual matters that often escape legal research.

Please find a sample chapter here.
For the table of contents please click here.