Annual Survey of International & Comparative Law


This article will examine the significance of transfer pricing. Further, it will review, as an example, the current national and international systems and procedures for identifying and capturing tax lost due to inaccurate transfer pricing used by two countries: the United States, as the originator and developer of much of the transfer pricing methodology, and Japan, one of the countries most actively involved in the regulation of transfer pricing and also a major trading partner of the United States. It will include a brief analysis of current issues and possible solutions to transfer pricing.