Transfer pricing litigation : a comparison

Journal
International Transfer Pricing Journal 2002 (Volume 9), No. 1
Contribution to the comparative survey : international aspects of transfer pricing litigation. Focused is on the extent to which documentation prepared in foreign countries is considered by tax courts in litigation; whether courts take notice of the fact that a transfer pricing case has been finalized without recourse to available information procedures; and, how the OECD Guidelines are considered by the tax courts in interpreting tax treaties and domestic transfer pricing provisions.