Transfer Pricing Viewpoint: Issue 2
31 August 2010
In this issue of Viewpoint, experts from NERA's Global Transfer Pricing Practice review three major recent transfer pricing cases -- Xilinx, Veritas, and GE Capital -- and draw attention to some of the lessons learned from these cases for taxpayers and transfer pricing practitioners. Although each of these cases is different and unique in its own way, it can be argued that all three boil down to selecting the most appropriate application of the arm's length principle -- the most fundamental concept in transfer pricing. The cases demonstrate that, when applying this principle, practitioners must be extremely cautious in using and interpreting third-party, market evidence to argue their case.
