International transfer pricing

Beginning with a brief introduction to the importance of international transfer pricing within the context of a global economy whose potential for interdependence is constantly growing, and the OECD's international BEPS project initiated by the G20, the focus will be primarily on the relevant articles of the OECD Model Tax Convention and the associated national income adjustment rules. To present the legal situation in its entirety, existing interpretative aids, such as the OECD Transfer Pricing Guidelines or the 2010 Transfer Pricing Guidelines, are covered, as are the procedural provisions of the Austrian Federal Tax Code relevant to transfer pricing. The aim is to provide the reader with a quick and clear overview of the legal situation in the field of international transfer pricing.