Fundamentals of International Transfer Pricing in Law and Economics

  • Wolfgang Schön
  • Kai A. Konrad

Part of the MPI Studies in Tax Law and Public Finance book series (MPISTUD, volume 1)

Table of contents

  1. Front Matter
    Pages I-XIII
  2. The Roles and Functions of Transfer Pricing in Organisations

  3. The OECD Approach to Transfer Pricing

  4. Transfer Pricing in Practice

  5. Separate Accounting, Profit Split and Formulary Apportionment

About this book


The taxation of multinational corporate groups has become a major concern in the academic and political debate on the future of international taxation. In particular the arm’s length standard for the determination of transfer prices is under increasing pressure.
Many countries and international bodies are now taking a closer look at the use of transfer prices for profit shifting and are exploring alternative mechanisms such as formulary apportionment for the allocation of taxing rights.
With regard to this topic, this volume is the first to offer a concise analysis of transfer pricing in the international tax arena from an interdisciplinary legal and economic point of view. Fundamentals such as the efficient allocation of resources within multi-unit firms and distortions between different goals of transfer pricing as well as different aspects of it in tax and corporate law, the traditional OECD approach and practical aspects concerning intangibles, capital and risk allocation are covered by outstanding authors.


Arm's Length Principle Formulary Apportionment International Taxation OECD Transfer Pricing Guidelines Transfer Pricing

Editors and affiliations

  • Wolfgang Schön
    • 1
  • Kai A. Konrad
    • 2
  1. 1.for Tax Law and Public Finance, Business and Tax LawMax Planck InstituteMunichGermany
  2. 2.for Tax Law and Public Finance, Public FinanceMax Planck InstituteMunichGermany

Bibliographic information

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