Transfer Pricing Past, Present and Future at WU

Once upon a time, in 1932, a lawyer named Mitchell Carroll was traveling through 27 countries to find the Holy Grail of international taxation: the arm’s length principle. That Holy Grail, initially conceived as a legal fiction having the ambition to allocate business profits to different countries in line with the way third parties would have done, has soon evolved into an economic principle.

Over the past 90 years, the (tax) human kind has been wondering how to interpret such legal fiction in a way that could reflect the economic reality in any allocation of business profits between parties of the same economic unit.

One of the most passionate explorers in this journey is Prof. Alfred Storck. During his career, shared between academia and practice, he has extensively worked on this principle, both by studying it in theory and by applying it in the context of a well-known multinational. However, Prof. Storck is more than an amazing professor, an incredibly experienced practitioner and a worldwide top-renewed expert. He is a guiding figure, an inspirational person and, of c...