 Back to Transfer Pricing
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| Comments to the Proposed Revision of Chapters I-III of the OECD Transfer Pricing Guidelines
8 January 2010 |
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Regulatory Filing
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| Application of Statistical Methods in Compliance with Transfer Pricing Rules in Japan
By Makoto Ikeya and Keita Fukunaga 20 August 2009 |
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Brief
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| Why Transfer Pricing is Relevant to Premiership Football Tax Planning International Transfer Pricing By Dr. Graham Poole, Pim Fris, and Tom Coriano 15 June 2009 |
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Published Article
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| Transfer Pricing in Troubled Times Tax Management Transfer Pricing Report By Nobuo Mori, Nihan Mert-Beydilli, and Dr. Graham Poole 15 May 2009 |
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Published Article
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| The New Temporary Cost Sharing Regulations: What Needs to be Done?
By Harlow N. Higinbotham, Stuart L. Harshbarger, and Wolf Witt 23 April 2009 |
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Brief
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| Cost Sharing Agreements May Allow Multinational Companies to Reap the Benefits of Intangible Asset Investment TPWeek.com By Nobuo Mori, Vladimir Starkov, and Yuko Saito 25 March 2009 |
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Published Article
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| Promulgation of the Implementation Measures for Special Tax Adjustments (Provisional)
By Yasunobu Suzuki and Charles Fu 19 February 2009 |
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Brief
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| Special Case: Charging Royalties to Newly Acquired Businesses
By Dr. Harlow Higinbotham, Dr. Stuart Harshbarger, and Wolf Witt 9 February 2009 |
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Brief
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| Transfer Pricing in France Tax Planning International Transfer Pricing By Sébastien Gonnet with Julien Monsenego of Dechert LLP 31 January 2009 |
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Published Article
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| Why Transfer Pricing Matters in Asset Management International Tax Review Intellectual Property By Dr. Emmanuel Llinares, Takefumi Suzuki, and Sylvain Gilibert 1 January 2009 |
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Published Article
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| How the OECD will Impact IP and Transfer Pricing International Tax Review Intellectual Property By Dr. Graham Poole and Dr. Emmanuel Llinares 1 January 2009 |
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Published Article
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| Documentation Requirements in Spain Tax Planning International Transfer Pricing By Victoria Alonso Cantero 1 December 2008 |
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Published Article
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| Transfer Prices Determined by Game Theory: Application to the Banking Industry Tax Planning International Transfer Pricing By Dr. Alexander Voegele, Sébastien Gonnet, Bastian Gottschling, and Hendrik Fügemann 1 December 2008 |
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Published Article
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| PEs and Transfer Pricing: The Playing Field in International Taxation Redefined Tax Planning International Transfer Pricing By Pim Fris, Dr. Emmanuel Llinares, and Sébastien Gonnet 1 December 2008 |
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Published Article
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| Using Credit Default Swaps to Price Intercompany Loan Guarantees
By Dr. Harlow Higinbotham and Dr. Stuart Harshbarger 20 November 2008 |
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Brief
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| Organisation et financement de la recherche et développement dans un contexte intra-groupe (R&D Organization and Financing in an Intra-Group Context) Bulletin Crédit Impôt Recherche By Dr. Emmanuel Llinares and Sébastien Gonnet 1 November 2008 |
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Published Article
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| Transfer Prices Determined by Game Theory: Application to IP Tax Planning International Transfer Pricing By Dr. Alexander Voegele, Sébastien Gonnet, and Bastian Gottschling
1 November 2008 |
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Published Article
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| New German Legislation: Relocation of Functions Tax Planning International Transfer Pricing By Dr. Alexander Voegele 1 October 2008 |
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Published Article
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| Transfer Prices Determined by Game Theory: Underlyings Tax Planning International Transfer Pricing By Dr. Alexander Voegele, Sébastien Gonnet, and Bastian Gottschling
1 October 2008 |
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Published Article
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| Focus on Profit Split Method BNA International's Transfer Pricing Manual By Dr. Alexander Voegele 1 September 2008 |
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Book Chapter
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| The Impact of OECD Developments on Transfer Pricing in the UK Euromoney Yearbooks' Transfer Pricing Review By Dr. Graham Poole 1 September 2008 |
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Published Article
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| Adjusting Uncontrolled Profit-Based Benchmarks for Differences in Operating Expense Structure Tax Planning International Transfer Pricing By Dr. Vladimir Starkov 30 August 2008 |
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Published Article
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| Compliance and Tax Planning Under the New US Service Fee Regulations
By Dr. Harlow Higinbotham and Dr. Stuart Harshbarger 7 August 2008 |
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Brief
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| Economic Analysis for Transfer Pricing: Attribution of Excess Profits and Intangible Asset Valuation
By Nobuo Mori, Yasunobu Suzuki, Takefumi Suzuki, Makoto Ikeya, and former NERA Senior Consultant Kei Maeda 31 July 2008 |
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Book
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| Japanese Transfer Pricing Regulations and a Case Study Taxation China By Yasunobu Suzuki 30 June 2008 |
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Book
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| France: Intangible Asset Remuneration Transfer Pricing Aspect of IP and Intangibles, a Tax Planning International Special Report By Jean-Sébastien Lénik with Yann de Kergos and Julien Monsenego of Dechert, LLP 31 March 2008 |
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Published Article
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| Pricing Intangible Property: The Path to a Sustainable Transfer Pricing System
By Jean-Sébastien Lénik 31 March 2008 |
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Brief
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| La loi allemande surles "Business Migrations ("The German Law on "Business Migrations") Edition Formation Entreprise By Sébastien Gonnet 10 February 2008 |
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Published Article
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| Contribution Analyses Under the Profit Split Method International Tax Review's Intellectual Property Supplement By Sébastien Gonnet and Pim Fris 31 December 2007 |
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Published Article
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| How Franchising Arrangements Could Apply in Transfer Pricing International Tax Review's Intellectual Property Supplement By Dr. Emmanuel Llinares and Nihan Mert-Beydilli 31 December 2007 |
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Published Article
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| Valuing Know-How and Knowledge through Bottom-Up Approaches International Tax Review's Intellectual Property Supplement By Dr. Alexander Voegele and Wolf Witt 31 December 2007 |
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Published Article
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| Willingness to Pay: How the Microeconomic Toolbox Applies to Brand Valuation International Tax Review's Intellectual Property Supplement By Dr. Alexander Voegele and Richard Sedlmayr 31 December 2007 |
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Published Article
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| IP Valuation Puts New Theories into Practice International Tax Review By Dr. Alexander Voegele, Wolf Witt, and Dr. Stuart Harshbarger 31 January 2007 |
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Published Article
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| Guidelines Address Migrating Business International Tax Review By Dr. Alexander Voegele and former NERA Consultant Dr. Stefan Lutz 31 January 2007 |
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Published Article
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| How Transfer Pricing Can Create Value International Tax Review's Intellectual Property Supplement By Pim Fris and Jean-Sébastien Lénik 31 January 2007 |
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Published Article
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| Gestion Stratégique des Prix de Transfert (Strategic Management of Transfer Pricing) EFE By Dr. Emmanuel Llinares and Sébastien Gonnet 31 December 2006 |
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Book Chapter
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| How to Determine Trade Marks Royalties International Tax Review By Dr. Emmanuel Llinares and Nihan Mert-Beydilli 31 December 2006 |
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Published Article
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| Chinese Transfer Pricing Regulations and Their Implications
By Pim Fris 12 December 2006 |
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Presentation
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| Intellectual Property Protection in China and Valuation of Intellectual Property
By Dr. Alan Cox 12 December 2006 |
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Presentation
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| US Perspectives on Marketing Intangibles and Services
By Dr. Harlow Higinbotham 12 December 2006 |
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Presentation
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| Japanese Perspectives on Marketing Intangibles
By Nobuo Mori 12 December 2006 |
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Presentation
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| Chinese Transfer Pricing Regulations and Practical Issues
By Yasunobu Suzuki 12 December 2006 |
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Presentation
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| A European View on Transfer Pricing After Glaxo Tax Planning International By Pim Fris and Sébastien Gonnet 30 November 2006 |
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Published Article
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| Identifying Relevant Intercompany Activities, Quantifying Measurable Benefits Under the Temporary US Services Rule Tax Management Transfer Pricing Report By Dr. Harlow Higinbotham and Dr. Stuart Harshbarger 25 October 2006 |
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Published Article
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| Culture Must Drive a Winning Policy International Tax Review By Dr. Emmanuel Llinares with Hervé Bidaud of Hogan & Hartson 15 October 2006 |
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Published Article
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| The Emergence of a European Dimension for Transfer Pricing Transfer Pricing Review 2006/07 By Pim Fris and Sébastien Gonnet 14 September 2006 |
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Published Article
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| Recent Transfer Pricing Perspectives in Japan -- Focus on Marketing Intangibles Transfer Pricing Review 2006/07 By Nobuo Mori 14 September 2006 |
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Published Article
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| Application of a Range to Determine Whether Transfer Pricing is Arm's Length International Taxation By Nobuo Mori, Makoto Ikeya, and Yaye Nakano 31 August 2006 |
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Published Article
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| ReAL Transfer Pricing: A New Paradigm for Transfer Pricing in Europe? Tax Planning International By Pim Fris and Sébastien Gonnet 15 June 2006 |
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Published Article
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| EU Arbitration for Financial Institutions Financial Solutions International By Dr. Alexander Voegele with Florence Forster of University Paris I, Sorbonne 31 May 2006 |
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Published Article
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| Transfer Pricing Documentation Transfer Pricing Documentation, a Tax Planning International Special Report By Dr. Alexander Voegele with Florence Forster of University Paris I, Sorbonne 30 April 2006 |
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Published Article
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| Mise en place d'une politique de prix de transfert et organisation d'une fonction fiscale performante (Implementing a Single Organization Function for Transfer Pricing Policy and Fiscal Performance) Reflets By Dr. Emmanuel Llinares 1 March 2006 |
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Published Article
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| Quantifying, Attributing Additional Profit from Location Savings Tax Management Transfer Pricing Report By Nobuo Mori and Makoto Ikeya 1 March 2006 |
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Published Article
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| The Arbitration of Transfer Prices in Europe: The EU Arbitration Convention in Practice Practical European Tax Strategies By Dr. Alexander Voegele with Florence Forster of University Paris I, Sorbonne 15 January 2006 |
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Published Article
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| How Analysis Can Define the Nature, Use and Pricing of Intangibles International Tax Review By Pim Fris and Sebastien Gonnet 15 December 2005 |
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Published Article
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| Calculating Royalties Based on Comparable Market Opinions International Tax Review By Alexander Voegele, Dr. Stuart Harshbarger, and Nihan Mert-Beydilli 15 December 2005 |
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Published Article
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| How to Use Transfer Pricing to Calculate the Value of a Brand International Tax Review By Alexander Voegele, Dr. Stuart Harshbarger, and Nihan Mert-Beydilli 15 December 2005 |
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Published Article
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| Intangibles, Market Structure and the Use of Profit Split Methods International Tax Review By Dr. Emmanuel Llinares 15 December 2005 |
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Published Article
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| New IRS Service Fee Regulations: The US Will Go First, Other Countries Will Be Forced to Follow Practical US/International Tax Strategies By Dr. Stuart Harshbarger 15 November 2005 |
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Published Article
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| Economic Approaches to Intellectual Property Policy, Litigation, and Management
Co-edited by Dr. Gregory K. Leonard and Dr. Lauren Stiroh 19 September 2005 |
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Book
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| Two Worlds Colliding? Transfer Pricing and Damages in Intellectual Property Litigation
By Dr. Phillip Beutel, Dr. Steven Schwartz, and Bryan Ray 15 June 2005 |
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White Paper
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| Die Verwaltungsgrundsätze zur Dokumentation von Verrechnungspreisen: Der Fremdvergleich und die Angemessenheit der Verrechnungspreise (Administrative Principles for the Documentation of Transfer Prices: The Analysis of Comparable Data and the Arm's Length Principle) Der Betrieb By Dr. Alexander Voegele 20 May 2005 |
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Published Article
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| A Market-Based Approach for Tangible Property Transfer Pricing BNA Tax Management Transfer Pricing Report By Dr. Richard Rozek with former NERA Senior Consultant Dr. George Korenko and former Consultant Emily Bishko Radel 16 March 2005 |
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Published Article
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| Germany's Draft Administrative Principles: Focus on Documentation, Economic and Quantitative Analysis Tax Management Transfer Pricing Report By Dr. Alexander Voegele and Thomas Tucha, with former NERA Consultant Dr. Markus Brem 10 November 2004 |
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Published Article
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| Dealing with Arm's Length and Comparability in the Years 2000 The International Transfer Pricing Journal By Pim Fris 1 December 2003 |
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Published Article
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| Using In-country Comparables to Measure the Returns Due Pharmaceutical Marketing and Distribution Affiliates The International Transfer Pricing Journal By Dr. Richard Rozek and former NERA Senior Consultant Dr. George Korenko 1 December 2003 |
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Published Article
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| Practical Solutions for Intercompany Pricing
By Dr. Harlow Higinbotham 15 November 2002 |
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Softbook
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| Common Flaws in Implementing Payment Terms Adjustments: The Effect of Benchmark Choice on the Arm's-Length Test BNA's Tax Management Transfer Pricing Report By Nihan Mert-Beydilli with former NERA Senior Analyst Esra Suzme 13 November 2002 |
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Published Article
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| Transfer Prices for the Intangible Property Embodied in Products with Extraordinary Profit Potentials Tax Notes International By Dr. Richard Rozek and former NERA Senior Consultant Dr. George Korenko 1 October 1999 |
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Published Article
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| When Arm’s Length Isn’t Really Arm’s Length: Issues in Application of the Arm’s-Length Standard Tax Management Transfer Pricing Report By Harlow Higinbotham with Marc. M. Levey 15 July 1998 |
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Published Article
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| Cross-Border Transactions Involving Intellectual Property: Valuation Under Internal Revenue Code Section 482 The California International Practitioner By Dr. Stuart Harshbarger with Dr. Anthony Barbera 7 January 1997 |
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Published Article
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| The Profit Split Method: Effective Application for Precision and Administrability The Tax Management Transfer Pricing Special Report By Dr. Harlow Higinbotham 2 October 1996 |
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Published Article
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| Applying the Best Method Rule When Reliable Internal Comparable Intangibles Exist Tax Notes International By Dr. Richard Rozek 8 April 1996 |
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Published Article
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| An Economic Perspective On the Best Method Rule: Intercompany Transfer Pricing Under the New Section 482 Regulations Worldwide Tax Daily, Special Reports By Dr. Harlow Higinbotham, with L. Guerard and D. Jankowski 22 March 1993 |
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Published Article
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| Effective Application of the Section 482 Transfer Pricing Regulations Tax Law Review By Dr. Harlow Higinbotham with D.W. Asper, P.A. Stoffregen and R.P. Wexler 1 December 1987 |
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Published Article
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