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Lawyers (and especially judges) tend to focus on those areas of law they are comfortable with when analyzing facts and applying the principles of law, developed by the interpretations of words and phrases they are used to seeing.

Pitch this alternative approach to the transfer pricing pundits, who as a matter of fact insist the OECD Transfer Pricing Guidelines and the methodologies proffered in those writings are gospel, and an interesting storm of ideas and concepts brew.  

The judges that face the taxpayer and revenue authorities to reason out who is right are mostly inexperienced and unknowledgeable in the field of transfer pricing. The pride of these lawyers is aptly overcome with: “Well, transfer pricing as a specialized field is no different to other areas of specialization we adjudicate upon, such as engineering and medicine.  We do not have to be specialists in those fields to judge.  We have expert witnesses to assist us in this regard.

There is truth in this statement, but as a transfer pricing specialist where transfer pricing legislation and the OECD and UN Transfer Pricing Guidelines are written specifically to guide transfer pricing related tax disputes, places transfer pricing on a different footing.  This will become apparent in this book and part of the reason why I decided to write it.  

This book is not supposed to be a technical piece of writing that analyses the OECD and UN TPGs and the tomes of articles available to research and analyse. It is a simple treatise to give practical guidelines on how to go about preparing for and conducting an ultimate TP trial.

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