Title

Location-Specific Advantages: A Rising Disruptive Factor in Transfer Pricing

Document Type

Article

Publication Date

2017

Source Publication

Bulletin for International Taxation 71(5)

Keywords

Transfer pricing; Location specific advantages; China

Abstract

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.