Transfer Pricing Viewpoint: Issue 1
17 June 2010
NERA Economic Consulting's Global Transfer Pricing Practice has launched Viewpoint, a new publication series aimed at providing regular commentary on developments in the world of transfer pricing from the viewpoint of economists who specialize in transfer pricing. Viewpoint will give insight into new ideas, thought leadership, and news by and from the practice. The inaugural issue of Viewpoint reviews three recent notable transfer pricing decisions -- DSG Retail Ltd (UK), Société Man Camions et Bus (France), and Glaxosmithkline (Canada) -- and highlights a number of points for transfer pricing practitioners. These points include: the importance of defining how to apply the arm's length principle, that the bar is being raised in comparability analysis and the making of adjustments; economics can, and is, being used to challenge and dismiss the positions advanced by taxpayers or tax authorities; and that tribunals and tax courts do, on occasion, appear to arrive at somewhat puzzling conclusions.
