This thesis examines the transfer pricing issue within the perspective of setting up a cost contribution arrangement for the international management of intangible property. / To this end, the first part presents the general rules governing the transfer pricing area in Australia, Canada, France, and the United States. The provisions of these countries will serve as a guiding line of this study. The first part presents, as well, the OECD Transfer Pricing Principles. / The second part examines the structural alternatives of the CCA tax vehicle. / The third part addresses the CCA concept itself. / The fourth part deals with the operational functioning of a CCA. The new challenges and the multiple issues raised by this new tax structure are addressed as well as the tax planning perspectives opening up through transfer pricing. / Finally, the fifth part questions the new dynamics of the conflicts between tax administrations generated by the CCA vehicle.
| Identifer | oai:union.ndltd.org:LACETR/oai:collectionscanada.gc.ca:QMM.30314 |
| Date | January 1999 |
| Creators | Lenik, Jean-Sébastien. |
| Contributors | Stevens, David (advisor) |
| Publisher | McGill University |
| Source Sets | Library and Archives Canada ETDs Repository / Centre d'archives des thèses électroniques de Bibliothèque et Archives Canada |
| Language | French |
| Detected Language | English |
| Type | Electronic Thesis or Dissertation |
| Format | application/pdf |
| Coverage | Master of Laws (Institute of Comparative Law.) |
| Rights | All items in eScholarship@McGill are protected by copyright with all rights reserved unless otherwise indicated. |
| Relation | alephsysno: 001740876, proquestno: MQ64290, Theses scanned by UMI/ProQuest. |
Page generated in 0.0022 seconds