Chapter 1
1. The Land of Punt, described in the chronicles of ancient Egypt, is somewhat of a mystery for we remain uncertain of its exact location. It is generally considered to be located in the regions of Djibouti, Eritrea, Ethiopia, and the Horn of Africa although many modern Egyptologists place it much closer to Egypt.
2. See chapter 7, entitled On Free Trade, in Ricardo (1817).
3. Based on the ratio of merchandise trade (exports and imports combined) to gross domestic product at current prices obtained from the United Nations Statistics Division and the OECD statistical service.
4. An excellent example of this is Elance Inc., which claims to be the world’s leading platform for online employment, helping organizations hire and manage in the cloud (see http://www.elance.com).
5. Fukuyama (1992).
6. In Australia, the French chemical giant SNF (Australia) successfully appealed against an Australian Tax Office–imposed penalty for transfer pricing and, in Canada, the Federal Court overturned a tax penalty on a Canadian pharmaceutical company for overpaying a Swiss affiliate for the active ingredient in the ulcer-fighting drug, Zantac.
7. Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations was published by the OECD in August 2010.