Precios de transferencia

Transfer pricing is a mysterious, intimidating and intricate legal fiction, according to David Rosenbloom in the foreword to the book Transfer pricing and dispute resolution (2011). Proving that an international transaction entered into between two related companies was carried out under the arm's length or Arm's Length principle - PPC - is often a complex task riddled with uncertain variables.

The book, in its first part, makes a conceptual sweep of the matter, consulting the OECD guidelines, the United Nations Manual, the United States tax legislation and countless authors. The second part addresses the empirical validity of the methods proposed by the OECD to evaluate compliance with the CPP, in a study supported by multiple business examples and judicial cases. The discussion is proposed from a novel academic and practical perspective, since, although recognized authors have questioned the PPC as a basis for evaluating the reasonableness of transfer prices, very few academics who accept said principle have discussed whether the application of the methods leads to valid conclusions.