Location-Specific Advantages: A Rising Disruptive Factor in Transfer Pricing
Journal
Country
China (People’s Rep.); International; OECD
Published Date
Issue
Bulletin for International Taxation 2017 (Volume 71), No. 5
Document
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.