Transfer pricing arms length principle international tax law analyzes the legal basis for the arms length principle and the contents of the principle in us tax law as well as the oecd model tax convention and transfer pricing guidelines it includes a thorough review of international case law on transfer pricing from the us canada australia united kingdom germany france the netherlands denmark sweden and norway. Series on international taxation v35 k4550 in international tax law the arms length principle states that multinational enterprises should carry out controlled transactions at arms length prices or prices which associated enterprises would have agreed to if they had made a comparable transaction on the open market rather than the . The proposed book analyzes the legal basis for the arms length principle and the contents of the principle in us tax law as well as the oecd model tax convention and transfer pricing guidelines it includes a thorough review of international case law on transfer pricing from the us canada australia united kingdom germany france the . As a result the irs estimates that there may be a tax gap as high as 345 billion based on improper transfer pricing strategies resulting in tax avoidance and evasion brian tully transfer pricing strategies and the impact on organizations financial executive july august 2012 hereinafter referred to as transfer pricing strategies. Transfer pricing arms length principle june 1962 the act provides that the tax payable in respect of international transactions is to be based on the arms length principle the tax payable by a resident party to an affected transaction containing a term or condition offensive to the arms length principle and the tax