Resolving Transfer Pricing Disputes: A Global Analysis (London: Cambridge University Press. 2012) (with Eduardo Baistrocchi)

Via a global analysis of more than 180 transfer pricing cases from 20 representative jurisdictions, Resolving Transfer Pricing Disputes explains how the law on transfer pricing operates in practice and examines how disputes between taxpayers and tax administrations are dealt with around the world. It has been designed to be an essential complement to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, which focus on transfer pricing issues but do not refer to specific transfer pricing disputes. All of the transfer pricing cases discussed in the book are linked to the relevant paragraphs of the OECD Guidelines by means of a 'Golden Bridge', namely a table listing the cases according to the paragraphs of the Guidelines to which they refer. It therefore provides examples of the application of the Arm's Length Principle in many settings on all continents.

click here for publisher's site

• Ian provides consulting advice on taxation matters regularly for the European Commission, HM Treasury and HM Revenue and Customs.

• He is a member of the European Association of Tax Law Professors , the International Fiscal Association (British Branch) and the Institute for Fiscal Studies.

Ian’s current research interests extend to international taxation, including the implications of taxation for development; European taxation and the influence of the European Court of Justice; corporate taxation; value added tax, including the application of the EC VAT Directives, the theory of VAT and the comparative development of VAT internationally; and tax avoidance and its implications for the development of tax systems.

LL293 Tax and Tax Avoidance

LL4AY International Tax Systems

LL4AZ Taxation of Multinational Enterprises: Transfer Pricing

LL4CG Tax Policy and Design

LL4CH Taxation of Transactions

LL4Z1 Business Taxation

LL4Z2 Principles of Taxation and Tax Disputes

 'Limits to globalisation: some implications for taxation, tax policy, and the developing world'. LSE law, society and economy working paper series, 3/2012 (2012)

'Interpreting exceptional VAT legislation: or, are there principles in Pringles?' B.T.R. 2010, 6, 699-716.

'Mobilx Ltd (In Administration) and others v HMRC: is this the end of fraudulent evasion of VAT?' B.T.R. 2010, 5, 492-500.

‘United Kingdom Country Report’ in G. Maisto (ed.), Tax Treaties and Domestic Law (Amsterdam: IBFD Publications, 2006)

‘Influence of Inflation’, in P. Essers and A. Rijkers (eds), The Notion of Income from Capital (Amsterdam: IBFD Publications, 2005) pp. 249-262

‘National Report United Kingdom’, in W. Schön (ed.), Tax Competition in Europe (Amsterdam: IBFD Publications, 2003) pp. 479-518

‘VAT Supplies of Services: A Definition in Search of a Meaning’, in A. Lymer and D. Salter (eds) Contemporary Issues in Taxation Research (Aldershot: Ashgate, 2003) pp. 169-200

‘General Anti-Avoidance in the United Kingdom’, in H. Erlichman (ed.), Tax Avoidance in Canada: The General Anti-Avoidance Rule (Toronto: Irwin Law, 2002) pp. 83-115

‘A limit on the purposive interpretation of VAT directives – Belgocodex v. Belgium’ [2000] British Tax Review 585-90

‘Assuring Real Freedom of Movement in Direct Taxation’ (2000) 63 Modern Law Review 831-76