The Oxford Handbook of International Business

By Alan M. Rugman; Thomas L. Brewer | Go to book overview

arm's length standard. This separate accounting framework worked reasonably well in the 'horse and buggy' days when multinationals were stand-alone replicas of their parents and most intrafirm transactions were in finished goods. As E-business spreads and more MNEs adopt transnational strategies and complex matrix structures, it will become increasingly difficult to apply separate accounting rules. The IRS has led the way by applying a formulary apportionment method to the global trading industry; perhaps this will be a bell-wether for future approaches to taxing MNEs in the twenty-first century.


References

Aitkinson, Mark, and Tyrrall, David (1999). International Transfer Pricing: A Practical Guide for Finance Directors. London: Financial Times Management.

Altshuler, Rosanne (2000). 'Recent Developments in the Debate on Deferral', Tax Notes International, 3 April: 1579-95.

Bird, Richard (1986). 'The Interjurisdictional Allocation of Income', Australian Tax Forum, 3/3: 333-53.

—— (1988). 'Shaping a New International Tax Order', International Bureau of Fiscal Documentation Bulletin, July: 292-9.

Cole, Robert T. (1999). Practical Guide to US Transfer Pricing. New York: Aspen Publishers.

Coopers and Lybrand (1998). International Transfer Pricing. Chicago, Ill.: CCH.

Culbertson, Robert (1995). 'A Rose by Any Other Name: Smelling the Flowers at the OECD's Last Resort', Tax Notes International, Aug. 7: 370-82.

Easson, Alex (1999). Taxation of Foreign Direct Investment: An Introduction. London: Kluwer Law International.

Economist, The (2000). 'The Mystery of the Vanishing Taxpayer. A Survey of Globalization and Tax', 29 Jan.

Eden, Lorraine (1998). Taxing Multinationals: Transfer Pricing and Corporate Income Taxation in North America. Toronto: University of Toronto Press.

—— Dacin, Tina, and Wan, William (forthcoming). 'Standards Across Borders: The Arm's Length Standard in North America', Accounting, Organizations and Society.

Emmanuel, Clive, and Mehafdi, Messaoud (1994). Transfer Pricing. San Diego, Calif.: Academic Press.

Ernst and Young (1997). Global Transfer Pricing Survey. Washington, DC: Ernst and Young International.

—— (1999). Global Transfer Pricing Survey. Washington, DC: Ernst and Young International.

Feinschreiber, Robert (ed.) (1998). Transfer Pricing Handbook, 2nd edn. New York: Wiley.

Hines, James (1999). 'Lessons from Behavioral Responses to International Taxation', National Tax Journal, 52/2: 305-22.

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