Transfer Pricing - Reading & Overall Reference List

Reading & Overall Reference List

International:

  • Wittendorff, Jens: Transfer Pricing and the Arm's Length Principle in International Tax Law, 2010, Kluwer Law International, ISBN 90-411-3270-8.

Canada:

  • Section 247 of the Income Tax Act (Canada)
  • Information Circular 87-2R - International Transfer Pricing (1999)
  • Information Circular 94-4R - International Transfer Pricing: Advance Pricing Arrangements (APAs) (2001)
  • TPM 07 - Referrals to the Transfer Pricing Review Committee (2005)
  • TPM 09 - Reasonable efforts under section 247 of the Income Tax Act (2006)

China: Major international accounting and law firms have published summaries of the guidelines. See their web sites.

India:

  • Income Tax Department's compilation of Transfer Pricing Rules

OECD:

  • OECD guidelines ISBN 978926409003, free view only version
  • OECD Transfer Pricing Country Profiles, a useful cross reference to guidance in each member country

United Kingdom:

  • Transfer pricing statute: ICTA88/Sch 28AA
  • HMRC International Manual Transfer Pricing INTM430000

United States:

  • Law: 26 USC 482
  • Regulations: 26 CFR 1.482-0 through 9
  • IRS view on OECD rules: http://www.irs.gov/pub/irs-apa/apa_training_oecd_guidelines.pdf
  • APA Procedure: Rev. Proc. 2008-31
  • Feinschreiber, Robert: Transfer Pricing Methods, 2004, ISBN 978-0-471-57360-9
  • Parker, Kenneth and Levy, Mark: Tax Director's Guide to International Transfer Pricing, 2008, ISBN 978-1-60231-001-8
  • Services by Thompson RIA and Wolters Kluwer: search "transfer pricing" on their websites

Russian Federation:

  • Tax Code of Russian Federation

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