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Article
Location-Specific Advantages: A Rising Disruptive Factor in Transfer Pricing
71(5) Bulletin for International Taxation 259
  • Jinyan Li, Osgoode Hall Law School of York University
  • Stephen Ji
Document Type
Article
Publication Date
1-1-2017
Keywords
  • Transfer pricing,
  • Location specific advantages,
  • China
Disciplines
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.

Citation Information
Jinyan Li and Stephen Ji. "Location-Specific Advantages: A Rising Disruptive Factor in Transfer Pricing" 71(5) Bulletin for International Taxation 259 (2017)
Available at: http://works.bepress.com/jinyan_li/157/