by Michael Lang
First published 2025
Transfer pricing litigation grows worldwide as jurisdictions clash over the arm's length principle. Michael Lang examines twenty pivotal court cases from fourteen countries, drawing from papers presented at the 2024 WU Transfer Pricing Symposium in Vienna. The analysis covers critical areas where transfer pricing rules intersect with legal burdens of proof, transaction recognition disputes, anti-abuse measures, intra-group losses, permanent establishment profit attribution, blocked income issues, and EU State Aid regulations. Each case study reveals how different courts interpret identical principles, creating a patchwork of conflicting precedents. Lang organizes the material by legal theme rather than jurisdiction, making patterns visible across borders. The book serves tax lawyers, in-house counsel, judges, academics, and tax authorities who need to understand how courts reason through complex transfer pricing disputes. It provides practical strategies for managing risks and strengthening legal arguments by leveraging global judicial trends.
Genres: reference, business, non-fiction, law, accounting, academic
Vibes: intimate, suspenseful, thought-provoking
Tropes: academic, legal-drama
Setting: Vienna, WU Transfer Pricing Symposium
Period: 2024, 2025
565 pages · Kindle Edition · Kluwer Law International