Document Type
Discussion Paper
Publication Date
2003
Abstract
The purpose of this chapter is to survey the judicial interpretations of transfer pricing, as developed in the cases decided under §482. The chapter is divided into three major sections: first, an overview of the general legal principles underlying the judicial interpretation of §482; second, a chronological survey of the development of the case law under §482, with particular attention to the development of the arm's length standard and the search for comparables; third, an analytical survey of the techniques used by courts to decide transfer pricing cases, with particular emphasis on the techniques developed in recent cases to deal with transfer pricing in the absence of com parables.
Recommended Citation
Avi-Yonah, Reuven S. "Analysis of Judicial Decisions Interpreting §482." In Transfer Pricing: Judicial Strategy and Outcomes, A-101 to A-131. Tax Management: Foreign Income Portfolios 888. Washington, D.C.: Tax Management, Inc., 2003.
Comments
© Tax Management Inc., a subsidiary of The Bureau of National Affairs, Inc. Reproduced with permission; all rights reserved.
Originally published as Avi-Yonah, Reuven S. "Analysis of Judicial Decisions Interpreting §482." In Transfer Pricing: Judicial Strategy and Outcomes, A-101 to A-131. Tax Management: Foreign Income Portfolios 888. Washington, D.C.: Tax Management, Inc., 2003.