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China (People’s Rep.)/International/OECD - Location-Specific Advantages: A Rising Disruptive Factor in Transfer Pricing

Country:
China (People’s Rep.),International,OECD
Author:
J. Li; S. Ji
Issue:
Bulletin for International Taxation, 2017 (Volume 71), No 5
Published:
22 March 2017
In this article, the authors consider location-specific advantages (LSAs) in transfer pricing analysis, with a special emphasis on the practice in China. They suggest that LSAs disrupt some of the basic assumptions underlying the current consensus on the application of the arm’s length principle without, arguably, violating the purpose of the principle as stated in article 9 of the OECD Model.
 
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