Stockholm university

Research project Transfer Pricing and the World Trade Organization Agreement

The compatibility of transfer pricing principles contained in Bilateral and Multilateral Tax Treaties with the WTO non-discrimination norms.

The overall purpose of my research is to conduct a legal analysis to determine whether WTO Members when applying transfer pricing measures are remaining compliant with their WTO obligations, and if not, whether such a conflict can be resolved. 

The reason for the overall purpose of my research is that transfer pricing measures have not been comprehensively exempted from the scope of the WTO Agreement, which could result in compatibility issues between international trade norms and transfer pricing norms, which have not been previously explored. Alternatively, my research could result in the conclusion that transfer pricing measures and the WTO Agreement are aligned and conflicts will not occur. If this is the case, my research would provide guidance on how tax and trade policymakers can remain compliant with their respective obligations should either area of international law be subject to future reform. 

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