Location-Specific Advantages: A Rising Disruptive Factor in Transfer Pricing
71(5) Bulletin for International Taxation 259
Transfer pricing; Location specific advantages; China
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.
Li, Jinyan and Ji, Stephen, "Location-Specific Advantages: A Rising Disruptive Factor in Transfer Pricing" (2017). Articles & Book Chapters. 2617.