Brattle Experts Propose a Global Value Chain Framework for Best Method Selection in Transfer Pricing Disputes
Published in Tax Notes International
Principals Drs. Ara Stepanyan and Bin Zhou and Senior Associate Dr. Haris Tabakovic propose that a systematic, theory-guided review of multinational enterprises’ contemporaneous make-or-buy and location decision-making processes could inform the application of section 482 in litigation.
Such a global value chain based framework could help bridge the gap between corporate strategy and tax litigation. Properly integrated with traditional benchmarking and financial analysis, this evidence can strengthen the reliability inquiry at the heart of the best method selection and potentially prevent protracted disputes.
The full article, “Corporate Strategy and Transfer Pricing: A Global Value Chain Framework for Best-Method Selection,” is available below.
