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ARTICLE · 02 MARCH 2001

Transfer Pricing And Electronic Commerce

United KingdomIntellectual Property
Jonathan Schwarz
Jonathan Schwarz

Introduction
Potential Difficulties
Applying The Transactional Approach
Comparability Analysis
Comparability Factors:-
Characteristics of property or services
Functional analysis:-
Disintermediation
Infrastructure providers
Contractual terms
Applying Traditional Transaction Methods
Integrated Businesses
Documentation

Introduction

The increased attention to transfer pricing matters by tax administrations accompanied by a flurry of legislative and regulatory developments in that area have coincided with the explosive commercialisation of the internet. Although there are no connections between the two, transfer pricing has been identified as one of the crucial challenges that electronic commerce poses to tax systems.

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