A Rethink of Location-Specific Advantages with an Analysis of the Chinese Approach

This article aims to provide an overview of the current debate on location-specific advantages (LSAs) and their implications for the future of transfer pricing research. With a special focus on the Chinese approach to LSAs, it compares the views of the OECD, the United Nations and the United States. Furthermore, it analyses LSAs from a conceptual, economic and transfer pricing perspective. In particular, this article identifies three issues arising from the LSA debate, namely the conflict between taxing MNEs and the arm’s length principle, the data constraints on local comparables and the increased concerns regarding marketing activities.